G.R. No. 124135 September 15, 1997
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANNY QUELIZA, accused-appellant.

FACTS

Accused-appellant Danny Queliza was convicted of Murder for the killing of Victoriano Cabangon. The prosecution established that on the night of October 30, 1992, the victim was asleep in his hut with his wife Teresita and their child. Teresita, who was awake, testified that Queliza suddenly pushed the door open and shot Victoriano in the head at close range, glanced at her, and fled. The victim’s mother, Loreta, corroborated this, testifying she saw Queliza arrive at the hut and later jump from it holding a gun after hearing a gunshot. The motive was traced to a prior quarrel between the appellant and the victim’s cousin, during which the victim sided with his cousin, prompting Queliza to threaten the victim’s life.
The defense presented an alibi, claiming Queliza was in Arnedo, Bolinao, swimming with cousins at the time of the incident. The trial court rejected this defense, giving greater weight to the positive identification by the eyewitnesses, and convicted Queliza of Murder qualified by treachery, sentencing him to reclusion perpetua and ordering him to pay civil damages.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt, particularly challenging the credibility of the prosecution witnesses and the rejection of the alibi defense.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, finding no reason to deviate from its conclusions. Teresita Cabangon’s positive identification of Queliza as the assailant was deemed credible, straightforward, and consistent. Her proximity to the event and the illumination from an electric bulb provided adequate opportunity for clear identification. The defense of alibi was correctly rejected as inherently weak and could not prevail over this positive identification, especially as the defense failed to prove it was physically impossible for Queliza to have been at the crime scene.
The Court affirmed the presence of treachery (alevosia). The attack was sudden and deliberate, directed at a sleeping and defenseless victim, ensuring the execution of the crime without risk to the assailant. However, the Court found that evident premeditation was not proven with the same clarity as the crime itself. Regarding civil liability, the Court modified the awards: it sustained the P50,000.00 civil indemnity, P9,500.00 compensatory damages, and P100,000.00 for loss of earning capacity but reduced the moral damages from P100,000.00 to a more reasonable P20,000.00. The penalty of reclusion perpetua was affirmed.