GR L 37080; (May, 1983) (Digest)
G.R. No. L-37080 May 3, 1983
The People of the Philippines, plaintiff-appellee vs. Romeo Salcedo, defendant-appellant.
FACTS
On February 15, 1971, in Mandaluyong, Rizal, Romeo Paguio was attacked and stabbed to death. The prosecution presented two eyewitnesses. Efren Barredo testified that he saw appellant Romeo Salcedo alight from a Cortina car, grab Paguio from behind, and stab him with a balisong. When Paguio broke free and ran, Salcedo chased him onto a vacant lot and continued stabbing him repeatedly despite his pleas. Barredo identified Salcedo, whom he knew, and noted Salcedo had three companions, one of whom was armed. Taxi driver Juanito Reyes, who had transported Paguio, corroborated the attack, identifying Salcedo as the assailant. The victim was brought to the hospital but died from his wounds.
The defense presented an alibi, claiming Salcedo was elsewhere at the time. The trial court convicted Salcedo of murder qualified by treachery and evident premeditation and imposed the death penalty. The case was elevated to the Supreme Court for automatic review.
ISSUE
Whether the guilt of the appellant for the crime of murder was proven beyond reasonable doubt.
RULING
Yes, the appellant’s guilt was proven beyond reasonable doubt, but the penalty is modified. The Supreme Court affirmed the conviction but reduced the penalty from death to reclusion perpetua. The Court found the testimonies of prosecution eyewitnesses Efren Barredo and Juanito Reyes credible and sufficient to establish appellant’s identity as the perpetrator. Their positive identification outweighed the weak defense of alibi. The Court explained that minor inconsistencies between a witness’s affidavit and court testimony are understandable and do not impair credibility, as affidavits are often incomplete. Barredo’s friendship with the victim’s family was not a motive to falsely testify against Salcedo, whom he also knew. Reyes’s initial reluctance to testify was reasonably explained by fear and inconvenience, and he had no motive to fabricate charges. The qualifying circumstances of treachery and evident premeditation were sufficiently proven by the sudden and deliberate attack, which ensured the victim had no chance to defend himself. However, with no generic aggravating or mitigating circumstances, the proper penalty is reclusion perpetua, not death. The judgment was modified accordingly.