G.R. No. 121778 September 4, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AARON BIONAT, accused-appellant.

FACTS

On August 12, 1985, at around ten o’clock in the evening, five armed men forcibly took Ernesto Romay from his house in Sitio Asuncion, Surallah, South Cotabato. The victim’s wife, Myrna Romay, witnessed the event and later identified accused-appellant Aaron Bionat as one of the perpetrators who pointed a gun at her. Ernesto was brought about seventy meters away and was found dead the next morning, bearing ten stab wounds. The prosecution established a land conflict as a possible motive, as the Romays were cultivating a two-hectare farm also claimed by a certain Escovidal, whom Bionat was seen escorting on the land after the killing.
The accused was charged with Murder. After being arrested in 1994, he pleaded not guilty. The trial court convicted him, finding the testimony of Myrna Romay credible. The defense presented alibi, claiming Bionat was elsewhere during the incident, and argued that Myrna’s initial failure to immediately name him and her later expressed willingness to execute an affidavit of desistance undermined her credibility. The trial court rejected these defenses and sentenced Bionat to reclusion perpetua.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused beyond reasonable doubt, particularly in light of challenges to the credibility of the sole eyewitness.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of Myrna Romay’s credibility, emphasizing that her positive identification of Bionat, whom she saw clearly by lamplight during the traumatic incident, was categorical and consistent. The delay in specifically naming him was reasonably explained by her need to verify his identity, which she did upon seeing him again in October 1985. The Court found that her subsequent actions, including pursuing the case for years despite the accused’s absence, demonstrated her resolve for justice.
The alleged affidavit of desistance did not materialize and was deemed a product of trickery by Bionat’s family, not a genuine recantation. The defense of alibi was correctly dismissed for being weak and unsubstantiated, especially against positive identification. The Court reiterated the doctrine that factual findings of the trial court, which had the direct opportunity to observe witness demeanor, are accorded high respect and are binding on appeal absent any clear oversight. No such oversight was found, and the evidence sufficiently established Bionat’s guilt for the crime of Murder.