GR 140897; (February, 2003) (Digest)
G.R. No. 140897 ; February 19, 2003
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EFIPANIA DELA CRUZ GO (at large) and RIZ JARLOS Y MATEO, accused. RIZ JARLOS Y MATEO, accused-appellant.
FACTS
Accused-appellant Riz Jarlos y Mateo was charged with Murder for the killing of Ronald Beda Pillejera. The prosecution presented eyewitness Arman Gunio, who testified that on November 20, 1997, in Marikina City, he saw a maroon Mitsubishi Space Wagon cut off a white Mitsubishi Lancer. The driver of the maroon vehicle, later identified as Jarlos, alighted, positioned himself at the driver’s side of the white car, and shot its driver, Pillejera. Gunio saw Jarlos’s face illuminated by the white car’s headlights. The autopsy by Dr. Anthony Llamas revealed the victim sustained sixteen gunshot wounds, including a close-range shot to the head. The defense presented alibi, claiming Jarlos was elsewhere, and attempted to impugn Gunio’s credibility, arguing the lighting was insufficient for identification.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt, particularly the credibility of the eyewitness identification and the presence of treachery to qualify the killing as murder.
RULING
The Supreme Court affirmed the conviction for Murder but modified the penalty to reclusion perpetua. The Court upheld the trial court’s assessment of eyewitness Gunio’s credibility, finding his testimony clear, consistent, and credible. The illumination from the victim’s car headlights provided adequate lighting for a positive identification, and there was no evidence of improper motive for the witness to falsely testify. The defense of alibi was correctly rejected for being weak and unsubstantiated. The Court agreed that treachery attended the killing. The medical evidence and eyewitness account established that the attack was sudden and deliberate, with the victim shot while seated and defenseless inside his car, ensuring the execution of the crime without risk to the assailant. However, the death penalty was reduced to reclusion perpetua. The Court applied Article 63 of the Revised Penal Code, which mandates the lesser penalty when no aggravating or mitigating circumstances are proven. The qualifying circumstance of treachery is inherent in the crime and does not count as a generic aggravating circumstance for penalty determination. The award of damages was also modified in line with prevailing jurisprudence.