G.R. No. 132330; November 28, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SPO1 JOSE BANGCADO and PO3 CESAR BANISA, accused-appellants.

FACTS

On the evening of June 27, 1993, victims Pacson Cogasi, Julio Clemente, Leandro Adawan, and Richard Lino were drinking at the Skyview Restaurant in Baguio City. Accused-appellants SPO1 Jose Bangcado and PO3 Cesar Banisa, both police officers, were seated nearby. When the victims left and proceeded to their parked vehicle, Bangcado and Banisa followed them. Under the pretext of conducting a frisk, the armed officers ordered the four men to line up against their Ford Fierra. Without any provocation, Bangcado suddenly fired his gun in quick succession at the lined-up victims. Adawan and Lino were killed instantly from gunshot wounds to the head. Cogasi was shot in the neck, and Clemente sustained two gunshot wounds to his right shoulder, with one bullet lodging below his right eye. Cogasi and Clemente survived and later filed a complaint.
The defense centered on the unreliability of the witnesses’ identification, particularly that of Clemente, due to his eye injury which allegedly blurred his vision. They also argued that the crime scene was poorly lit, making positive identification impossible. The prosecution presented evidence of well-lit conditions both inside the restaurant and at the parking area, and detailed the proximity and interaction between the victims and the assailants prior to the shooting.

ISSUE

Whether the positive identification of the accused-appellants by the prosecution witnesses is credible and sufficient to sustain their conviction for murder and frustrated murder beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court meticulously addressed the defense’s challenges to the witnesses’ identification. It ruled that the conditions for a reliable identification were present. The restaurant and the immediate vicinity of the shooting were sufficiently illuminated by various light sources, allowing the victims to clearly see the appellants’ faces. The Court emphasized the victims’ proximity to their assailants—as close as one meter—and the extended interaction during the frisking and questioning, which provided ample opportunity for a clear view. While Clemente’s vision was impaired, Cogasi’s positive and consistent identification alone was deemed sufficient for conviction. The Court reiterated the doctrine that the testimony of a single credible witness is adequate for a finding of guilt, as witnesses are weighed, not numbered. The appellants’ denial and alibi could not overcome the positive, categorical, and consistent identification by the eyewitness. The qualifying circumstance of treachery was correctly appreciated, as the execution of the attack, wherein the unarmed and compliant victims were summarily shot while lined up, ensured their defenselessness without any risk to the appellants. The penalties and damages imposed by the trial court were affirmed.