G.R. No. 123109 June 17, 1999
People of the Philippines vs. Juan Taclan y Paronga, Danilo Taclan y Laluz, Nemesio Alcantara y Giriganda, and Perfecto Gasta y Quevido

FACTS

Accused Juan Taclan, Danilo Taclan, Nemesio Alcantara, and Perfecto Gasta were charged with murder for the killing of Carlos Taclan. The prosecution’s lone eyewitness, Enrique Lagondino, testified that in the morning of February 20, 1994, he saw Juan angrily shout at Carlos, the victim, near Carlos’s hut. Later that afternoon, while fishing, Enrique saw Juan, Danilo, Nemesio, and Perfecto hide near a guava tree. When Carlos passed by, Juan suddenly struck him on the nape, causing him to fall. The group then carried Carlos. Danilo hacked him with a bolo, Nemesio stabbed him, and Danilo further slashed him with a knife. Perfecto fetched water poured on the body. Traumatized, Enrique initially remained silent but eventually revealed what he saw to the victim’s widow in April 1994.
The accused denied involvement, interposing alibi. They claimed they were either working in their fields or drinking together during the time of the incident. The trial court convicted Juan, Danilo, and Nemesio as principals in murder qualified by treachery, and sentenced them to reclusion perpetua. Perfecto was convicted as an accomplice. Only the three principals appealed.

ISSUE

The core issue is whether the trial court erred in convicting the accused-appellants based primarily on the credibility of the lone eyewitness, Enrique Lagondino, despite his delayed reporting of the crime.

RULING

The Supreme Court affirmed the conviction. The delay of Enrique Lagondino in reporting the crime did not impair his credibility. The Court recognized that witnesses to a shocking crime, especially in rural settings, may initially be reluctant to come forward due to fear, trauma, or a desire to avoid involvement. Enrique’s fright from witnessing the brutal killing was a valid and sufficient reason for his initial silence. His eventual disclosure, prompted by conscience, and his detailed, consistent, and graphic testimony identifying the appellants and describing their concerted actions, carried the hallmark of truth.
The Court found conspiracy among the appellants. Their collective actions—lying in wait, the synchronized attack following Juan’s signal, and the use of weapons by multiple assailants—demonstrated a common design to kill Carlos. The crime was qualified by treachery. The attack was sudden, without warning, and rendered the unarmed and unsuspecting victim incapable of any defense. While abuse of superior strength was present, it was absorbed by treachery. Evident premeditation was not proven. The defense of alibi, unsupported by clear proof of the physical impossibility of the appellants’ presence at the crime scene, could not prevail over Enrique’s positive identification.