G.R. No. 171087 ; July 12, 2006
PEOPLE OF THE PHILIPPINES, appellee, vs. FABIAN SADES y RODEL, appellant.

FACTS

On December 26, 2000, at around 1:00 a.m., Bienvenido Fallarna Roga was shot and killed at the doorway of his house in Oriental Mindoro. The prosecution’s principal witness was Marilyn Roga, the victim’s wife and the sister of the appellant, Fabian Sades. Marilyn testified that she and her husband went to their doorway upon hearing their dog bark. She stated she was standing side-by-side with her husband when she saw her brother, the appellant, shoot him once with a short firearm. She identified the appellant clearly under the illumination of an improvised lamp (moron) located more than an arm’s length away. After the shooting, the appellant fled, and the victim walked to the kitchen before collapsing.
The appellant interposed the defense of alibi. He claimed he was at home sleeping at the time of the incident and was only awakened by his children when Marilyn arrived to seek help for her wounded husband. He asserted he could not assist because he was sick and had sore eyes, so he instead instructed his sons-in-law to help. The trial court convicted him of Murder qualified by treachery and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction with modifications to the damages awarded.

ISSUE

Whether the prosecution proved the guilt of the appellant for the crime of Murder beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the appellant’s conviction. The Court upheld the credibility of Marilyn Roga’s positive identification. The defense’s attack on her testimony for alleged inconsistencies was unavailing, as minor discrepancies do not undermine credibility but may even enhance it by negating rehearsed testimony. The Court found her account clear, straightforward, and consistent on the material point of identifying her brother as the assailant at close range under adequate illumination. Her natural interest as the victim’s widow would be to secure justice, not to falsely accuse her own brother.
The Court rejected the weak defense of alibi, which cannot prevail over the positive identification by a credible witness. The qualifying circumstance of treachery was correctly appreciated because the attack was sudden and unexpected, depriving the unarmed victim of any chance to defend himself. The Court sustained the penalty of reclusion perpetua and the awards of civil indemnity, actual damages for funeral expenses, and moral damages for the mental anguish suffered by the victim’s heirs.