G.R. No. 212930 , August 3, 2016
People of the Philippines, Plaintiff-Appellee, vs. Angelo Buenafe y Briones @ “Angel,” Accused-Appellant.

FACTS

On March 24, 2005, around 10:00 PM, at Alpa Farm in San Pedro, Laguna, 15-year-old farmhand Kenneth dela Torre witnessed the killing of his employer, Rommel Alvarez. Kenneth saw accused-appellant Angelo Buenafe and two unidentified men alight from a vehicle. While Rommel was unwarily texting inside a tent, the two men restrained his arms from behind. Appellant then approached and delivered several blows to Rommel’s abdomen, causing him to crumple. The two men dragged Rommel to a nearby hut where appellant shot him using a lead pipe (“sumpak”). Appellant and his companions then fled. Kenneth initially kept silent out of fear but later revealed what he saw to Rommel’s wife, Marissa Alvarez, on April 22, 2005, after being overwhelmed by conscience. Appellant was charged with Murder, qualified by treachery and abuse of superior strength. He pleaded not guilty, denying the accusations and claiming he was at a “pabasa” until 10:00 PM and then went home. He also pointed to the negative results of fingerprinting and paraffin tests conducted on him the day after the incident. The Regional Trial Court found him guilty of Murder and sentenced him to reclusion perpetua, ordering him to pay civil indemnity, moral damages, and exemplary damages. The Court of Appeals affirmed the RTC decision.

ISSUE

Whether the Court of Appeals committed reversible error in affirming appellant’s conviction for Murder based on the testimony of eyewitness Kenneth dela Torre, despite appellant’s defenses of denial, alibi, lack of motive, and the negative forensic test results.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court ruled that:
1. Treachery was present, qualifying the killing as Murder. The victim was unwarily texting when suddenly restrained, then repeatedly punched, dragged, and shot, with no opportunity to defend himself, and the means were deliberately adopted to ensure execution without risk.
2. The positive identification by eyewitness Kenneth prevails over appellant’s denial and alibi. The witness had no motive to falsely testify against appellant, who had even recommended him for the job. The trial court’s assessment of witness credibility is accorded great respect.
3. Motive is irrelevant when the accused is positively identified, and intent to kill was established by the manner of the crime’s commission.
4. The delay in the witness coming forward does not impair credibility, as it was explained by his initial fear.
5. The negative paraffin and fingerprint test results are not conclusive of innocence, as they do not rule out the possibility of the crime being committed as described.
6. The aggravating circumstance of abuse of superior strength is absorbed in treachery.
The penalty of reclusion perpetua was affirmed. Appellant was ordered to pay the heirs of the victim Php75,000 as civil indemnity, Php75,000 as moral damages, Php75,000 as exemplary damages, and Php50,000 as temperate damages, with 6% interest per annum from the finality of judgment.