GR L 28596; (February, 1968) (Digest)
G.R. No. L-28596 February 21, 1968
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SANTIAGO TILOS, defendant-appellant.
FACTS
Santiago Tilos and Rolando Banhao were detention prisoners in the Negros Occidental provincial jail. On January 6, 1965, they were under the custody of provincial guard Francisco Castillo and were taken to the jail yard. That evening, Rolando Castillo, the son of the guard, invited Tilos and Banhao to go with him to a dance hall about 100 meters away. After initial hesitation from Banhao, the trio left the jail through the rear gate. At the dance hall, Banhao stayed outside while Rolando Castillo and Tilos entered. Later, a shower occurred, causing people to exit the hall. Banhao witnessed Tilos stab a man, Gaudencio Olivas, who later died from the wound. Tilos and Rolando Castillo then ran back to the jail, followed by Banhao. An information for murder was filed against Tilos and Rolando Castillo, but only Tilos was tried as Castillo remained at large. The defense claimed Tilos never left the jail, presenting a “Custodian’s Report” and testimonies to support this. The trial court found Tilos guilty of murder and sentenced him to reclusion perpetua.
ISSUE
Whether the trial court erred in convicting Santiago Tilos of murder based on the credibility of the prosecution’s eyewitness and the sufficiency of evidence establishing treachery.
RULING
The Supreme Court affirmed the trial court’s judgment. The Court held that the credibility of prosecution eyewitness Rolando Banhao was not impaired by his prior quarrel with Tilos over jail food rations, as such friction was insufficient to cause a false testimony for a grave offense like murder. The trial court’s findings on credibility were upheld absent serious reasons to reject them. The defense’s “Custodian’s Report” was not conclusive, as the defense’s own witness, guard Francisco Castillo, testified he had taken Tilos into his custody that day. The Court found that treachery was adequately established because Tilos stabbed the victim during a shower when people were exiting the dance hall in confusion, taking advantage of the situation to conceal his act and facilitate escape. Thus, the conviction for murder and the penalty of reclusion perpetua were correct.