G.R. No. 130550 September 2, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANDRES PEÑAFLORIDA, accused-appellant.

FACTS

Accused-appellant Andres Peñaflorida was charged with murder, along with two unidentified persons, for the killing of SPO3 Eusebio Natividad on October 5, 1994, in San Ildefonso, Bulacan. The information alleged the killing was attended by treachery, evident premeditation, and abuse of superior strength. Peñaflorida pleaded not guilty. The prosecution’s primary witness was Rodolfo de la Cruz, who testified that at around 4:00 p.m., while resting on his terrace about five armslength from a small market, he witnessed an owner-type jeep carrying Natividad being blocked by three armed men. One shouted, “Natividad katapusan mo na ito,” after which all three simultaneously fired at Natividad. One assailant then took Natividad’s wallet and gun before fleeing. On October 12, 1994, de la Cruz voluntarily went to the 175th PC Detachment, where he identified Peñaflorida as the assailant who took the wallet and gun, and executed a sworn statement. In court, de la Cruz positively identified Peñaflorida. The defense presented alibi, with Peñaflorida claiming he was at his brother’s house in Marulas, Bulacan, assisting in auto repairs at the time of the incident, and only left on October 11 to harvest palay, when he was arrested. His brother corroborated this. The trial court found de la Cruz’s testimony credible and convicted Peñaflorida of murder, sentencing him to reclusion perpetua and ordering him to indemnify the victim’s heirs P50,000.

ISSUE

Whether the trial court erred in convicting accused-appellant based on his positive identification by the eyewitness, Rodolfo de la Cruz.

RULING

The Supreme Court affirmed the conviction. The trial court’s assessment of witness credibility is accorded great respect and finality absent any showing it overlooked material facts. The Court found that de la Cruz had a clear view of the crime from a short distance (five armslength) and positively identified Peñaflorida, both at the police detachment and in open court. The short time of observation did not negate his ability to remember the assailants’ faces, and there is no legal requirement for a police line-up for proper identification. The delay of seven days in executing a sworn statement did not impair credibility, and there was no proof of coaching by the police. The defense of alibi, uncorroborated and self-serving, cannot prevail over positive identification. The qualifying circumstances of treachery, evident premeditation, and abuse of superior strength were correctly appreciated, as the attack was sudden and executed in a manner ensuring the victim’s defenselessness. The penalty of reclusion perpetua and civil indemnity of P50,000 were affirmed.