G.R. No. 91539 September 30, 1991
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAMON SAMPAGA, accused-appellant.

FACTS

Accused-appellant Ramon Sampaga was charged with Murder for the killing of Antolino Alba, the Chief Barangay Tanod of Asid, Masbate, on the night of March 9, 1988. The prosecution’s case rested primarily on the eyewitness account of Felix Malunes, a fellow tanod who accompanied the victim. Malunes testified that he, the victim, and another tanod were instructed to check a dance permit at a party near Aristoteles Pacheco’s house. Upon arrival, as Antolino conversed with Pacheco, Sampaga suddenly emerged from the victim’s left side, about six feet away, and shot him with a short gun. The scene was illuminated by a petromax lamp. Malunes and his companion immediately reported the shooting to the victim’s father, Barangay Captain Generoso Alba, identifying Sampaga as the assailant.
The defense interposed denial and alibi. Sampaga, who claimed to be the barangay captain, testified he was at the same dance but did not see the victim there and denied owning a gun or committing the crime, alleging the victim was a relative. He claimed he only learned he was a suspect a week later from a local tabloid. Other defense witnesses testified to his good character. The trial court convicted Sampaga of murder qualified by treachery and sentenced him to reclusion perpetua.

ISSUE

Whether the trial court erred in convicting the accused-appellant of murder based on the credibility of the prosecution’s eyewitness and in appreciating the qualifying circumstance of treachery.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, finding no reason to deviate from its conclusions. The positive identification by eyewitness Felix Malunes, who was familiar with the accused as a fellow barriomate and had a clear view under sufficient illumination, prevailed over the weak defenses of denial and alibi. The Court noted that Malunes had no motive to falsely testify, and the brief delay in giving a formal police statement did not impair his credibility, as he reported the identity of the assailant immediately on the night of the crime.
The Court agreed that treachery attended the killing. The attack was sudden and unexpected, as Sampaga emerged and shot the victim while the latter was engaged in conversation, giving him no opportunity to defend himself or escape. This method directly insured the execution of the crime without risk to the assailant. The decision was affirmed with modification, increasing the civil indemnity to P50,000.00 and clarifying that the proper penalty is reclusion perpetua, not life imprisonment.