G.R. No. L-13288; June 30, 1960
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSE NARANJA, defendant-appellant.

FACTS

The accused, Jose Naranja, was charged with and convicted of murder for the killing of Mamerto Signey on the night of December 28, 1956, in Dasol, Pangasinan. The prosecution’s case relied heavily on the testimony of Maria Diaz, the victim’s wife. She testified that on the afternoon of the crime, the accused came to her house. She told him to stop visiting because her husband knew of their illicit relationship. The accused, who had previously asked her to leave her husband, stated he would find a way to separate them and told her to wait for him that evening. When she asked why, he said he would kill her husband, who was then harvesting palay. That evening, after her husband went outside following barking dogs, Maria Diaz went to the kitchen and saw the accused at the stairs. The accused confessed to her that he had killed her husband, instructed her to retrieve and bury the body at the creek east of the house, and warned her not to tell anyone. She then alerted her mother and neighbors, including Santiago Balderas, who helped recover the body. A medical examination revealed a bluish-black spot on the nape of the deceased, and Dr. Valera opined a blow to the medulla oblongata could cause instantaneous death. The defense presented an alibi, claiming the accused was elsewhere harvesting rice, but the trial court found this weak and not physically impossible given the proximity of the crime scene.

ISSUE

Whether the guilt of the accused for the crime of murder has been established beyond reasonable doubt.

RULING

Yes, the conviction is affirmed. The Supreme Court held that the accused’s guilt was proven beyond reasonable doubt. The testimony of Maria Diaz was found credible and not self-serving, as she gained no beneficial interest and even exposed her own dishonor to reveal the truth. Her account of the accused’s confession before and after the killing was admissible as part of the res gestae (statements made during or immediately after a startling occurrence). This confession was corroborated by the physical evidence (the wound on the victim’s nape and the medical opinion) and by the testimony of Santiago Balderas, who confirmed that Maria Diaz reported her husband’s death and its location. The defense of alibi was rejected as weak and incredible, especially since the accused could have traveled from the alleged harvesting site (about one kilometer away) to commit the crime. The appealed decision was affirmed.