GR 96923; (May, 1996) (Digest)
G.R. No. 96923 . May 24, 1996.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENANTE PARAGUA and EDGARDO PARAGUA, accused-appellants.
FACTS
On December 3, 1988, in Barangay Limbon, Sariaya, Quezon, eyewitness Bartolome Umila was with the victim, Dennis Baladad, and others at a house. Accused-appellants Renante and Edgardo Paragua were present. Renante made a cross sign, stating it was for Umila and Baladad. The appellants left, and about ten minutes later, Umila and Baladad also departed, walking towards Baladad’s house. While Umila walked ahead, he heard Baladad cry out. Turning his flashlight, he saw both appellants stabbing Baladad with a bladed weapon, with Edgardo holding the victim. When Renante lunged at him, Umila ran to his parents’ house, reported the incident, and returned to find Baladad dead.
The appellants were charged with Murder. The prosecution relied primarily on Umila’s eyewitness account. The defense consisted of alibi and denial, with both appellants claiming they were at their respective homes at the time of the incident. Their fathers corroborated their whereabouts. The trial court convicted them as principals of Murder qualified by treachery.
ISSUE
Whether the trial court erred in convicting the accused-appellants of Murder based on the lone testimony of the eyewitness and in finding the crime attended by treachery.
RULING
The Supreme Court affirmed the conviction. The appeal lacked merit. The positive identification by eyewitness Bartolome Umila prevailed over the weak defenses of alibi and denial. The Court emphasized that alibi and denial are inherently weak defenses, especially when weighed against the affirmative testimony of a credible witness who had no improper motive to testify falsely. Umila’s conduct of running to his parents after being threatened by the appellants was a natural human reaction to a frightening event and did not impair his credibility.
The Court also upheld the finding of treachery (alevosia). The attack was sudden, executed at nighttime, and rendered the victim defenseless as he was held and stabbed. The nature and number of wounds—thirty-six stab wounds—indicated a deliberate effort to ensure the killing without risk to the assailants. This method squarely qualified the killing as Murder under Article 248 of the Revised Penal Code. The trial court’s assessment of witness credibility and factual findings were accorded finality, as no substantial reason was shown to overturn them.