G.R. No. 191063; October 9, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ALDRIN M. GALICIA, Accused-Appellant.

FACTS

Accused-appellant Aldrin Galicia was charged with Murder for the killing of Judge Voltaire Rosales. The Information alleged that on June 10, 2004, Galicia, conspiring with Jun Asuncion (who remained at large), acted as the driver of a getaway motorcycle while Asuncion shot the victim inside his vehicle in Tanauan City. The prosecution presented two eyewitnesses. Maricel Flores testified that she interacted with two men near her carinderia shortly before the shooting; one man (later identified as Galicia) was standing beside a black motorcycle. After hearing gunshots, she saw the same two men speed away on the motorcycle driven by Galicia. Ramil Enriquez corroborated this, testifying he saw the two riders of a black motorcycle, with Galicia driving, fire upon the victim’s vehicle before fleeing.
The defense, presented through PNP-SOCO investigators, attempted to cast doubt on the identification. They testified that their initial investigation report indicated the assailants wore “black bonnets,” implying witnesses could not have seen their faces. Galicia denied involvement and claimed the witnesses could not have positively identified him.

ISSUE

Whether the prosecution proved the guilt of accused-appellant Aldrin Galicia for the crime of Murder beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimonies of prosecution eyewitnesses Flores and Enriquez to be credible, positive, and consistent. They provided detailed accounts of Galicia’s presence and active participation as the driver of the getaway motorcycle immediately after the shooting. The defense’s reliance on the SOCO report mentioning “black bonnets” was insufficient to discredit this direct eyewitness identification. The Court ruled that such a general initial report does not negate the possibility that the witnesses saw the perpetrators’ faces at close range before the crime, as Flores did when she spoke to them. Galicia’s role as the driver established his indispensable participation in the conspiracy to commit the murder. By facilitating the swift escape, he ensured the execution of the crime and the assailants’ evasion of capture. The qualifying circumstance of treachery was duly proven, as the attack was sudden and deliberate, rendering the victim defenseless. The Court modified the damages awarded, ordering Galicia to pay civil indemnity, moral damages, and exemplary damages to the victim’s heirs, all with legal interest.