G.R. No. 138017 . February 23, 2001.
PEOPLE OF THE PHILIPPINES, petitioner, vs. ARNULFO “MIKE” NATIVIDAD, JUN CABAONG, SESINANDO “BOY” LLERINA (at large) and VICENTE MILLADO, accused. ARNULFO “MIKE” NATIVIDAD, accused-appellant.

FACTS

On February 20, 1989, inside the Ramos, Tarlac police station, appellant Mayor Arnulfo “Mike” Natividad, appearing intoxicated, shot victim Severino Aquino in the forehead at point-blank range. The incident was witnessed by several police officers on duty. The prosecution established that the victim was earlier brought to the station by accused Jun Cabaong. Appellant interrogated the victim, became enraged when the latter could not answer coherently, and struck him with a gun before ordering the windows closed and executing the shooting. Afterward, appellant ordered the body disposed of; it was later found dumped in another municipality. The police officers present, including SPO2 Felipe Padua and SPO3 Reynaldo Daileg, did not immediately report the crime. They testified that appellant tore the relevant page from the police logbook that same night.
The case for murder was filed years later. At trial, the prosecution presented the eyewitness accounts of the police officers. The defense, after its demurrer to evidence was denied and a motion to dismiss based on an affidavit of desistance from the victim’s heirs was rejected, opted not to present any evidence. The Regional Trial Court convicted appellant of murder and sentenced him to reclusion perpetua. Appellant appealed, challenging the credibility of the police witnesses due to their four-year delay in reporting the incident.

ISSUE

Whether the delay of four years by the police officers in revealing information about the crime impairs their credibility to such a degree that appellant’s guilt was not proven beyond reasonable doubt.

RULING

No, the delay does not impair their credibility. The Supreme Court affirmed the conviction. The legal logic rests on the principle that delay in reporting a crime, by itself, does not automatically render a witness’s testimony false or unreliable. The Court found the delay was sufficiently explained by the witnesses’ reasonable fear of reprisal from appellant, who was the municipal mayor and a person of considerable power and influence in the community. This fear is a natural reaction and does not undermine the evidentiary weight of their positive and categorical testimonies, which were consistent on material points and described the incident in a straightforward manner.
The Court emphasized that the assessment of witness credibility is best undertaken by the trial court, and its findings are accorded great respect. Here, the trial court found the police officers’ testimonies credible. Their collective account positively identified appellant as the perpetrator who shot the unarmed and helpless victim. Appellant’s failure to present any contrary evidence, choosing instead to rely on the presumption of innocence, could not prevail against the strong, direct, and unrebutted evidence of the prosecution. The qualifying circumstance of treachery was correctly appreciated, as the attack was executed in a manner that ensured the victim had no opportunity to defend himself. Thus, the conviction for murder was upheld.