G.R. No. 33526 ; January 22, 1931
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. JUAN ALAMBRA and ELENO GARCIA, defendants-appellants.

FACTS

The defendants, Juan Alambra and Eleno Garcia, were charged with the crime of murder for the killing of Fulgencio Casupang on December 26, 1929, in Carranglan, Nueva Ecija. The information alleged the qualifying circumstances of treachery, evident premeditation, and cruelty. After trial, the Court of First Instance found them guilty of murder qualified by treachery and sentenced each to cadena perpetua. The defendants appealed, contesting the credibility of the prosecution’s key eyewitness, a 14-year-old boy named Mercurio Tambuyac, and the probative value of an alleged admission of guilt (Exhibit B) by appellant Juan Alambra.

ISSUE

1. Whether the trial court erred in giving full credit to the testimony of the young eyewitness, Mercurio Tambuyac.
2. Whether the trial court erred in considering Exhibit B as an admission of guilt by appellant Juan Alambra.

RULING

The Supreme Court affirmed the conviction.
1. The trial court did not err in crediting the testimony of the 14-year-old eyewitness. The Court upheld the trial judge’s assessment of the witness’s competence and credibility, noting that the witness gave a clear and simple account of the crime. The Court cited authority stating that an intelligent boy, whose observations are not yet clouded by life’s biases, can be one of the best observers and witnesses.
2. The Court found it unnecessary to rule on the admissibility or probative value of Exhibit B. It held that, independent of that exhibit, the evidence—primarily the credible eyewitness testimony—was sufficient to prove the defendants’ guilt beyond a reasonable doubt. The crime was committed with treachery, as the attackers hid and suddenly assaulted the victim, qualifying the killing as murder.
The penalty of cadena perpetua and the other dispositions of the trial court were affirmed.

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