G.R. No. 180281; July 01, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JOEMARIE JALBONIAN alias “Budo”, Accused-Appellant.

FACTS

An Information for Murder was filed against Joemarie Jalbonian for stabbing Fortunato Quintanilla, Jr. to death on January 26, 1991, in Ilog, Negros Occidental. The prosecution’s sole eyewitness was Barangay Chairman Oscar Valenciano. He testified that after a barangay assembly, he saw appellant, from a distance of about three-arms length, position himself behind the victim and stab him in the back with a knife before immediately fleeing. Valenciano ordered a chase, but appellant escaped. The victim died from the wound. Appellant evaded arrest for over five years. The defense presented no evidence after its demurrer to evidence was denied.

ISSUE

Whether the testimony of a lone eyewitness is sufficient to prove the guilt of the accused for murder beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction. The Court emphasized that the testimony of a single witness, if credible and positive, is sufficient for a conviction. Valenciano’s testimony was found credible. As Barangay Chairman, he was familiar with the appellant. He gave a clear, consistent, and straightforward account of the broad daylight attack from a short distance, observing the positioning and the stabbing motion. His lack of ill motive to falsely testify bolstered his credibility. The physical evidence, stipulated through the death certificate showing a fatal stab wound on the back, corroborated his account. Appellant’s flight for over five years was a further indication of guilt. Regarding the qualifying circumstance, the Court ruled that treachery was present. The attack was sudden from behind, ensuring the victim had no opportunity to defend himself. The mode of execution was deliberately adopted to accomplish the crime without risk to the assailant. The conviction for murder was thus upheld, and the award of damages by the Court of Appeals was sustained.