G.R. No. 130596 ; February 15, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO CASTILLANO alias “RODEL”, accused-appellant.

FACTS

On the evening of August 20, 1996, Ramil Hijapon was conversing with his wife, Lucia, inside their small, well-lit store in Bacolod City. Their son, Buenaventura, was also present. Without any warning, appellant Rodolfo Castillano approached the store, drew a .38 caliber revolver, inserted it through the jalousie window, and fired twice at Ramil. The first shot hit Ramil in the chest, while the second shot missed as Lucia pulled her husband away, instead hitting the concrete wall. Castillano then fled. The victim died from the gunshot wound. The prosecution established a prior grudge, as the victim had previously filed an attempted homicide case against Castillano after an earlier shooting incident in 1994.
The defense presented an alibi, claiming Castillano was at a different location attending a birthday party at the time of the shooting. The trial court rejected this defense, giving full credence to the positive and categorical testimonies of the eyewitnesses—the victim’s wife and son. The Regional Trial Court convicted Castillano of murder qualified by treachery and sentenced him to reclusion perpetua. He appealed, challenging the credibility of the witnesses and the finding of treachery.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellant beyond reasonable doubt and correctly established the qualifying circumstance of treachery for the crime of murder.

RULING

The Supreme Court affirmed the conviction. The positive identification by two eyewitnesses who had no ill motive to testify falsely prevails over the weak alibi of the appellant. The witnesses were in close proximity, the area was well-lit, and they knew the appellant from previous encounters, making their identification credible and reliable.
On the qualifying circumstance, the Court upheld the finding of treachery. The attack was sudden and unexpected, executed in a manner that deprived the unarmed victim, who was merely conversing inside his store, of any opportunity to defend himself or retaliate. The appellant employed means of execution that directly and specifically ensured the commission of the crime without risk to himself. The Court modified the damages awarded, ordering the appellant to pay the victim’s heirs moral damages of ₱50,000.00 and temperate damages of ₱15,000.00, in addition to the civil indemnity already imposed by the trial court.