G.R. No. L-32196 April 20, 1982
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FILOMENO ROALLOS, ANTONIO ROALLOS and NESTORIO ANOG, accused-appellants.

FACTS

On the evening of December 21, 1968, in Barrio Alupay, Rosario, Batangas, Camilo Magnaye was shot and killed. The prosecution’s eyewitness, Isagani Ramos, testified that he saw appellants Filomeno Roallos, Antonio Roallos, and Nestorio Anog lying in wait near the house of PC Sergeant Francisco Kalalo. As the victim passed by, Filomeno fired a carbine at close range while Antonio and Nestorio simultaneously fired .45 caliber pistols. The initial volley felled Magnaye, after which the assailants fired additional shots. Ramos, who had known the appellants for a decade, positively identified them under the illumination of a Coleman lamp from the house. The post-mortem examination revealed multiple gunshot wounds, with one wound to the heart being mortal.
The defense consisted of alibi and denial. Antonio Roallos and Nestorio Anog claimed they were elsewhere during the incident. They also attacked Ramos’s credibility, suggesting his testimony was fabricated due to a grudge. Notably, two other individuals initially named as witnesses, Remigio Ilao and Lucio Mangundayao, recanted their prior statements implicating the appellants. Paraffin tests showed positive results for nitrates on the hands of Filomeno and Antonio, but a negative result for Nestorio.

ISSUE

The core issue is whether the prosecution proved the guilt of appellants Antonio Roallos and Nestorio Anog beyond reasonable doubt, primarily hinging on the credibility of the lone eyewitness testimony against their defenses of alibi and the recantation of other witnesses.

RULING

The Supreme Court affirmed the conviction. The trial court’s assessment of witness credibility is accorded great weight, and it rightly found the testimony of Isagani Ramos credible and sufficient to establish guilt. Ramos provided a clear, consistent, and detailed account of the ambush, including the positions of the assailants and the sequence of shots. His long-standing familiarity with the appellants bolstered the reliability of his positive identification, which was made under adequate lighting. The defense of alibi, being inherently weak, cannot prevail over this positive identification.
The recantations of Ilao and Mangundayao were correctly disregarded. Recantations are notoriously unreliable and are viewed with extreme caution, as they can easily be obtained through coercion or monetary consideration. The Court upheld the principle that a testimony given in open court under oath holds more weight than a subsequent retraction. Furthermore, the physical evidence corroborated Ramos’s account. The paraffin tests, while negative for Nestorio Anog, were not exculpatory, as expert testimony established that a negative result does not conclusively prove a person did not fire a gun, which can be affected by factors like wearing gloves or washing hands. The trajectory and nature of the victim’s wounds were consistent with the described assault from multiple assailants at close range. Thus, the prosecution successfully proved conspiracy and the qualifying circumstance of treachery, as the attack was sudden and afforded the victim no opportunity to defend himself.