GR 88822; (July, 1996) (Digest)
G.R. No. 88822 July 15, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALEJANDRO TUVILLA Y MAGAYO, accused, NELSON ALUNAN Y ASTURIAS, accused-appellant.
FACTS
Accused-appellant Nelson Alunan, along with Alejandro Tuvilla, was charged with Murder for the stabbing death of Ronaldo Javier on April 25, 1982, at the Orig Restaurant in Bacolod City. The prosecution’s eyewitness, waitress Angelita Flores, testified that appellant and Tuvilla entered the restaurant, drank beer, and later positioned themselves near the victim’s table. She saw them go to the comfort room and then exit. Concerned about their unpaid bill, Flores followed and witnessed Tuvilla stab the victim from behind while holding him. After the victim fell, both appellant and Tuvilla lifted him and stabbed him repeatedly before fleeing. The victim died upon arrival at the hospital. The trial court convicted appellant and Tuvilla of murder, sentencing them to reclusion perpetua. Appellant appealed, arguing the witness’s testimony was unreliable and that the trial court erred in appreciating conspiracy and treachery.
ISSUE
The core issue is whether the prosecution proved appellant’s guilt for the crime of murder beyond reasonable doubt, particularly concerning the credibility of the eyewitness account and the presence of qualifying circumstances like treachery.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of eyewitness Angelita Flores’s credibility, finding her testimony clear, consistent, and credible. She had a clear view of the incident, provided positive identification of the appellant, and her narration of events was straightforward. The Court emphasized that factual findings of the trial court on witness credibility are accorded great weight. The defense of denial, which appellant interposed, is inherently weak and cannot prevail over positive identification. Regarding the qualifying circumstance, the Court found that treachery (alevosia) was duly established. The attack was sudden and from behind, giving the victim no opportunity to defend himself. This manner of execution ensured the assailants’ safety from any retaliation. The Court modified the civil indemnity, increasing it to P50,000.00 in line with prevailing jurisprudence, but sustained the penalty of reclusion perpetua.