GR 122769; (August, 2000) (Digest)
G.R. No. 122769 ; August 3, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENANTE GONZALES @ “Oyong” and BLAS ROSARIO, accused. BLAS ROSARIO, accused-appellant.
FACTS
The prosecution established that on the evening of March 10, 1990, Angelo de Guzman was seated inside his well-lit house in Dagupan City when accused-appellant Blas Rosario, positioned outside a window, shot him at close range with a shotgun. The other accused, Renante Gonzales, supported Rosario’s arm. The victim’s wife, Violeta, who was only a meter away, positively identified both assailants, whom she knew personally. The defense presented alibis. Rosario claimed he was in Urbiztondo, Pangasinan, until 8:30 PM before traveling to Dagupan for supplies. The trial court rejected the alibis, noting the proximity of the locations made his presence at the crime scene possible, and found the accused guilty of murder.
ISSUE
Whether the trial court erred in convicting accused-appellant Blas Rosario of murder based on the eyewitness testimony of Violeta de Guzman, which he claims is contradictory and highly improbable.
RULING
The Supreme Court affirmed the conviction. The appeal primarily challenged the credibility of the lone eyewitness, Violeta. The Court reiterated the settled doctrine that the assessment of witness credibility is best left to the trial court, which observes the witness’s demeanor, and its findings are accorded great respect unless shown to be arbitrary. The Court found no reason to deviate from this rule. The alleged inconsistencies in Violeta’s testimony—such as her failure to warn her husband upon seeing suspicious activity or minor discrepancies regarding who precisely held the firearm—were deemed inconsequential. The Court explained that there is no standard behavioral response to a startling event, and the core fact of positive identification remained unrebutted. The minor detail about the exact distance from which the shot was fired was also immaterial to the established fact of the accused’s presence and participation. The killing was qualified by treachery, as the attack was sudden, from behind, and ensured the victim, who was unarmed and watching television, had no opportunity to defend himself. The penalty of reclusion perpetua was thus affirmed.