G.R. No. 119007 October 4, 1996
People of the Philippines vs. Romulo Soria y Galletes

FACTS

The prosecution established that on the evening of April 7, 1992, in Solana, Cagayan, accused-appellant Romulo Soria entered the house of Felix Bago, where the victim Patricio Reyes and his mother Aurea were present. Soria, armed with a gun, immediately fired at Felix Bago but missed. A second shot hit Patricio in the arm. Felix managed to flee, with Soria chasing and firing at him unsuccessfully. Soria then returned to the house and shot Patricio, who was lying wounded on the floor, causing his death. Aurea Reyes, who hid under a table, witnessed the final shooting from a distance of two meters under fluorescent lighting and positively identified Soria, whom she knew very well.
The defense presented an alibi, claiming Soria was at Leonardo Bago’s house, three kilometers away, slaughtering and cooking dogs for a barangay meeting from the afternoon until about 11:00 PM of the same day. The trial court rejected this defense.

ISSUE

The core issues on appeal were: (1) the credibility of the lone eyewitness, Aurea Reyes; (2) the sufficiency of the prosecution evidence to prove guilt beyond reasonable doubt; and (3) the presence of treachery to qualify the killing as murder.

RULING

The Supreme Court affirmed the conviction for murder. The Court upheld the trial court’s assessment of witness credibility, emphasizing that the firsthand observations of the trial judge on witness demeanor are accorded the highest respect. Aurea Reyes’s testimony was found credible and consistent; she had a clear view of the accused under adequate lighting and knew him personally. Her natural reaction of hiding did not negate her ability to identify the assailant.
The defense of alibi was correctly dismissed. For alibi to prevail, the accused must demonstrate it was physically impossible for him to be at the crime scene. The distance of three kilometers between the locations did not constitute such impossibility. The positive identification by a credible eyewitness prevails over a weak alibi.
Regarding treachery, the Court agreed with the trial court’s finding. The attack was sudden and deliberate, ensuring the victim had no opportunity to defend himself. The initial shooting created a state of helplessness, and the accused’s return to shoot the already wounded and prone victim confirmed the deliberate execution without risk to himself. This method squarely constitutes treachery, qualifying the homicide as murder. The decision of the Regional Trial Court was affirmed in toto.