G.R. No. L-17401, November 28, 1964
People of the Philippines vs. Santiago Raquel

FACTS

On June 1, 1959, during a fiesta in Leyte, Francisco Dador was shot while eating supper inside a house. His wife, Julita Arboso, immediately went to seek help and, upon exiting, saw the accused Santiago Raquel aiming a gun at her. Raquel told her, “Your husband will not live again.” Dador, before dying from the gunshot wound over a month later, identified Raquel as the shooter and stated a motive related to a prior case. Raquel interposed an alibi, claiming he was elsewhere delivering goods at the time.

ISSUE

Whether the trial court erred in convicting the accused of murder based primarily on the testimony of the victim’s wife, Julita Arboso.

RULING

The Supreme Court affirmed the conviction. The Court found Julita Arboso’s testimony credible, natural, and spontaneous. Her act of seeking help immediately after the shooting was a reasonable and courageous response, not an incredible one. The positive identification by the eyewitness, coupled with the weak and physically possible alibi (as the distance between the crime scene and the accused’s alleged location was not prohibitive), sufficiently established guilt. The shooting from behind, at night, while the victim was eating, constituted treachery, qualifying the crime as murder. The penalty of reclusion perpetua was proper, and the civil indemnity was modified.