G.R. No. L-29129. May 8, 1975.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOMINGO MABUYO, defendant-appellant.

FACTS

On June 18, 1966, Norberto Anillo was shot dead at his home in Tanauan, Batangas. His widow, Adelaida Mirania, testified that upon hearing her husband call to open the door, she went downstairs with a lamp. She heard gunshots, her husband cry out, and upon opening the door, saw appellant Domingo Mabuyo firing a carbine at her prostrate husband. She immediately identified Mabuyo to her arriving father-in-law, Agaton Anillo. Another witness, Aniceto Sumarraga, testified that two days prior, Mabuyo had solicited his help to kill Anillo, which he refused. Agaton Anillo corroborated that his son had earlier warned him of a plot by Mabuyo.
The defense presented an alibi, claiming Mabuyo was in Gabaldon, Nueva Ecija, from June 3, 1966, until his surrender on March 27, 1967, and was allegedly detained in the Gabaldon municipal jail for drunkenness on the night of the murder. To support this, the defense presented a police blotter entry. The prosecution, however, presented evidence that Mabuyo had prepared a bail bond as early as March 4, 1967, indicating prior knowledge of the charges against him, and that his prolonged absence from his family suggested flight.

ISSUE

The core issue is whether the prosecution proved the guilt of Domingo Mabuyo for the crime of murder beyond reasonable doubt, overcoming his defense of alibi.

RULING

The Supreme Court affirmed the conviction. The alibi defense was thoroughly discredited. The police blotter entry presented to show Mabuyo’s detention was found unreliable; the Chief of Police himself expressed surprise at its irregular placement, and evidence suggested the payrolls covering his alleged employment were fabricated en masse. Crucially, Mabuyo’s actions contradicted his claim of ignorance. He had secured a bail bond in February 1967, long before his alleged discovery of the charges in March, proving he was aware of his implication. His nine-month absence from his barrio, without even a Christmas visit, strongly indicated flight, not innocent employment.
The Court upheld the finding of treachery. The attack was sudden and employed a high-powered firearm on a victim who was knocking at his door, rendering him defenseless. The mitigating circumstance of voluntary surrender was correctly denied, as his appearance nearly nine months after the warrant’s issuance lacked spontaneity. With murder qualified by treachery and no modifying circumstances, the penalty of reclusion perpetua was proper. The Court modified the decision only by increasing the civil indemnity to the heirs from P6,000 to P12,000.