G.R. No. 95049, December 9, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NESTOR ESCANDOR and FIDEL ESCANDOR, accused-appellants.

FACTS

On December 2, 1988, victim Sabino Huelva and his three children were walking along a trail in Baleno, Masbate. They met appellants Nestor and Fidel Escandor, father and son, walking in the opposite direction. As the groups passed each other, Nestor suddenly and without warning shot Sabino in the back. When Sabino tried to rise, Fidel shot him in the upper right breast, causing him to slump to the ground. The victim’s children, including eyewitness Glenn Huelva, scampered away. Glenn immediately reported the incident to his mother and barangay officials. The police later found Sabino dead at the scene with gunshot wounds.
The appellants were convicted of murder by the Regional Trial Court. Nestor was sentenced to an indeterminate penalty, while Fidel was meted reclusion perpetua. They appealed, challenging the credibility of the lone eyewitness, Glenn Huelva, and asserting their respective defenses of self-defense and alibi. They argued that Glenn’s testimony was biased due to his relationship with the victim and contained inconsistencies.

ISSUE

The core issue is whether the prosecution evidence, primarily the testimony of Glenn Huelva, is sufficient to sustain the conviction for murder beyond reasonable doubt, overcoming the defenses raised.

RULING

The Supreme Court affirmed the conviction but modified the penalties. The Court upheld the trial court’s assessment of Glenn Huelva’s credibility. Relationship to the victim alone does not impair a witness’s credibility, and the trial court, which observed his straightforward testimony, found him credible. The alleged inconsistencies in his testimony—regarding whether his siblings ran before or after the shooting—were minor and pertained to insignificant details; such minor inaccuracies can even suggest truthfulness. The Court also found nothing unbelievable in the sudden, unprovoked attack or the children’s shocked reaction, noting that criminals often act without warning to ensure success.
The defenses of self-defense and alibi were rejected. For self-defense, the burden of proof shifts to the accused, which Nestor failed to discharge with clear and convincing evidence. His claim was uncorroborated and inconsistent with the physical evidence. Alibi, inherently weak, was likewise unavailing as Fidel failed to prove it was physically impossible for him to be at the crime scene. The qualifying circumstance of treachery was correctly appreciated, as the attack from behind was sudden and without warning, ensuring the execution without risk to the assailants. The Court modified Nestor’s penalty to an indeterminate sentence of 10 years and 1 day of prision mayor maximum as minimum to 20 years of reclusion temporal maximum as maximum. Fidel’s reclusion perpetua was affirmed. Civil indemnity was increased to P50,000.00.