G.R. No. L-38725. May 15, 1979.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO ARTIEDA, defendant-appellant.

FACTS

The case involves the killing of Simeon Rivera. Prior to the incident, Rivera had been charged with the killing of appellant Antonio Artieda’s brother but was acquitted. On the evening of May 8, 1972, in Nagcarlan, Laguna, Rivera and his wife, Apolonia Heraldo, were in their home when several men, including Antonio Artieda, Rodolfo Artieda, Venancio Dorado, and Bernabe Artieda, arrived claiming to be authorities. They forcibly seized Rivera, tied his hands behind his back, and took him away. Apolonia witnessed the abduction and recognized the assailants but, out of fear for her and her son’s safety, did not immediately reveal their identities to authorities. Rivera’s body was discovered days later in a forested area, bearing multiple stab wounds, with his hands still bound.

ISSUE

The core issues for review are: (1) the credibility of the prosecution’s eyewitness, Apolonia Heraldo; (2) the sufficiency of her testimony to establish appellant’s guilt beyond reasonable doubt; and (3) the proper characterization of the crime and the attendant circumstances.

RULING

The Supreme Court affirmed the conviction for Murder but reduced the penalty from death to reclusion perpetua. The Court upheld the trial court’s assessment of Apolonia Heraldo’s credibility. Her initial reluctance to identify the assailants was satisfactorily explained by her genuine and reasonable fear for her life, given the violent nature of the crime and the threat she perceived. Her subsequent positive identification of appellant in court was deemed credible and sufficient for conviction, as the testimony of a single witness, if credible and positive, can meet the standard of proof beyond reasonable doubt. The defense of alibi was correctly rejected, as it was not physically impossible for appellant to have been at the crime scene.
The killing was qualified by treachery. The victim was seized from his home, his hands were bound, rendering him utterly defenseless, and he was killed in such a bound state. This method of attack ensured the execution of the crime without risk to the assailants. The circumstance of nocturnity was absorbed in treachery. The alleged cruelty was not proven, as there was no evidence the wounds were inflicted to deliberately prolong suffering. The Court also ruled that an extrajudicial confession made by appellant during the pendency of the appeal could not be considered a mitigating circumstance of a plea of guilty, as it was not made at the first opportunity before the trial court. With treachery as the sole qualifying circumstance and no other modifying circumstances, the proper penalty is reclusion perpetua.