G.R. No. L-32733 September 11, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALFONSO MANANGAN, alias ONSONG, accused-appellant.

FACTS

In the early morning of November 13, 1968, Alejo Cayago and his wife Rosalina were asleep in their house in Mangatarem, Pangasinan. They were awakened by a noise from their carabao’s corral. Suspecting theft, Cayago went to the open bamboo porch (batalan) to urinate. While there, he was shot five times from below and died instantly. Rosalina, upon hearing the shots, took a flashlight and went to the batalan. She saw her husband’s body and beamed her light towards a fleeing person. The light illuminated the face of Alfonso Manangan, her compadre and a neighbor, who was four meters away, armed with a carbine, and wearing a distinctive hat. Manangan turned and shot at Rosalina three times, grazing her leg, before fleeing with companions.
The police investigation recovered empty shells, and the medico-legal officer confirmed the trajectory of the bullets was upward, indicating the assailant was positioned below the victim. The motive established was Manangan’s resentment towards Cayago, whom he suspected of reporting him for stealing a fishing net. This animosity was demonstrated in an altercation between the two about twelve days prior to the killing. After a manhunt, Manangan was arrested, charged, and convicted of murder by the trial court, which sentenced him to reclusion perpetua.

ISSUE

The core issues on appeal were: (1) whether the conviction based primarily on the eyewitness testimony of the victim’s wife, Rosalina Cayago, was reliable; and (2) whether the qualifying circumstance of treachery and the generic aggravating circumstance of evident premeditation were sufficiently proven.

RULING

The Supreme Court affirmed the conviction for murder but modified the ruling on the aggravating circumstances. The Court upheld the credibility of Rosalina Cayago’s testimony. Her positive identification of Manangan was deemed credible and sufficient for conviction. She knew him well as a compadre and neighbor, the illumination from her flashlight and the moonlit night provided adequate visibility, and her account was consistent with the physical evidence regarding the shooter’s position. Her immediate disclosure of the assailant’s identity to the barrio captain bolstered her credibility.
The Court affirmed the presence of treachery (alevosia). The attack was sudden and unexpected, executed in a manner that ensured the victim had no opportunity to defend himself. Cayago was unarmed and in the act of urinating on an elevated porch, making him a helpless target for shots fired from the dark ground below. This method directly and specially ensured the execution of the crime without risk to the assailant.
However, the Court found that evident premeditation was not conclusively proven. While prior ill will existed, evidenced by the altercation days before, the prosecution failed to establish the required elements: clear proof of the time the offender decided to commit the crime, overt acts showing he clung to that decision, and a sufficient interval for cool reflection between the decision and the execution. The evidence did not detail the planning steps taken after the initial quarrel. Consequently, with treachery as the sole qualifying circumstance and no other aggravating or mitigating factors, the penalty was properly imposed in its medium period, which is reclusion perpetua. The trial court’s judgment was affirmed.