G.R. No. 89662 . October 1, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANCISCO VILLABLANCA and EDUARDO VILLABLANCA, accused-appellants.

FACTS

Accused-appellants Francisco Villablanca and Eduardo Villablanca, brothers, were charged with Murder for the killing of Pedro Natanio on August 19, 1985, in Pastrana, Leyte. The information alleged conspiracy, treachery, and abuse of superior strength. They pleaded not guilty. The prosecution’s primary witness was the victim’s 17-year-old daughter, Elizabeth Natanio. She testified that past midnight, she, her father, and her brother were asleep when appellants forced open their door. Francisco made Pedro kneel and stabbed him in the stomach with a samurai, while Eduardo pointed a gun at Pedro’s face. Francisco stabbed Pedro three more times. Elizabeth recognized the appellants by beaming her flashlight on their faces, as they were known to her; Francisco was a friend of her father, and Eduardo was her friend. She cried out, and Francisco threatened to kill her, but Eduardo said to spare her due to her youth. The appellants then left. Pedro was brought to the hospital but died en route from multiple stab wounds. The trial court found the appellants guilty of murder qualified by treachery and abuse of superior strength and sentenced them to reclusion perpetua and indemnity. Appellants appealed, assailing the credibility of Elizabeth’s testimony.

ISSUE

Whether the trial court erred in convicting the accused-appellants based on the testimony of a single eyewitness, Elizabeth Natanio, which they claim was fraught with inconsistencies and improbabilities.

RULING

The Supreme Court denied the appeal and sustained the conviction. The testimony of a single witness, if positive and credible, is sufficient to support a conviction for murder. The trial court, which had the unique opportunity to observe the witness’s demeanor, found Elizabeth’s testimony to be straightforward, candid, and credible. She positively identified the appellants, and her identification was express, direct, and explicit. The alleged inconsistencies (e.g., whether the stabbing occurred in the bedroom or living room) were minor and did not impair her trustworthiness, especially given the small size of their house. The defense of alibi cannot prevail over positive identification. The qualifying circumstances of treachery and abuse of superior strength were properly appreciated as the attack was sudden and the assailants were armed with a bladed weapon and a gun against a crippled victim. The penalty of reclusion perpetua was affirmed, and the civil indemnity was increased to P50,000.00 in line with prevailing jurisprudence.