G.R. No. L-73804 May 29, 1987
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELIPE BRAVANTE and AUGUSTO ALTAREJOS, accused-appellants.

FACTS

The accused-appellants, Felipe Bravante and Augusto Altarejos, were convicted of murder by the Regional Trial Court of Masbate for the killing of Miguel Nuevo on December 24, 1983. The prosecution’s evidence established that in the evening of said date, the victim, his eight-year-old son Jose, and a companion, Nilo Bauso, were on their way home when appellants suddenly approached them near Bravante’s house. Without any warning, Bravante, armed with a spear, attacked the unarmed victim, hitting him on the arm and chest. When Nuevo fell, Altarejos, armed with a bolo, hacked him on the forehead and neck, causing his instantaneous death. The post-mortem examination revealed fatal wounds consistent with the weapons used.
The defense presented a different version, primarily alleging self-defense by Bravante and alibi by Altarejos. Bravante claimed the victim and Bauso attacked him first, forcing him to retaliate. Altarejos denied participation, asserting he was elsewhere during the incident. The defense also presented a witness, Pelagio Tuca, to support their narrative and challenged the credibility of the child eyewitness, Jose Nuevo.

ISSUE

The core issue is whether the trial court erred in convicting the appellants of murder, qualified by treachery, and in rejecting their defenses of self-defense and alibi.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the evaluation of evidence and the presence of treachery. The Court found the testimony of the young eyewitness, Jose Nuevo, to be credible and consistent. His account detailed a sudden and unprovoked attack on his unarmed father by two armed assailants, leaving the victim no opportunity to defend himself. This manner of execution perfectly constitutes treachery, which qualifies the killing as murder. The means employed—a surprise assault with deadly weapons—directly and specially ensured the execution of the crime without risk to the attackers arising from any defense the victim might make.
The defenses of self-defense and alibi were correctly rejected. For self-defense, the burden of proof shifts to the accused, which Bravante failed to discharge. The nature, number, and location of the victim’s fatal wounds were inconsistent with a struggle and were more indicative of a determined assault. The claim of voluntary surrender was also belied by records showing his arrest months later. For alibi, it is inherently weak and cannot prevail over the positive identification by a credible eyewitness. The trial court’s assessment of witness credibility is accorded high respect, and no compelling reason was shown to overturn its findings. Thus, the guilt of both appellants was proven beyond reasonable doubt.