G.R. No. L-75390, March 25, 1988
PEOPLE OF THE PHILIPPINES, appellee, vs. DANILO VALDEZ and SINIPLICIO ORODIO alias “Kamlon”, appellants.

FACTS

On the evening of June 7, 1977, in Santol, La Union, the Maquiling family was in their yard. The victim, Eleno Maquiling, was seated and about to stand up to accompany a relative when a loud gunshot from the northern side of the yard struck him in the back, causing his instantaneous death. His mother, Esmenia, and brother, Dionisio, immediately looked toward the source of the gunfire. Both testified that they saw appellants Danilo Valdez and Simplicio Orodio running away from the bamboo groves on the hill, with Valdez carrying a long firearm. The area was illuminated by a petromax lamp. The appellants were well-known to the eyewitnesses.
The autopsy revealed eight gunshot wounds on the victim’s back from a shotgun. Investigation showed that three days prior, Eleno had disclosed to his father a quarrel with the appellants over their alleged thievery, expressing fear for his life. The initial police investigation did not immediately yield the eyewitness accounts, as the family members were reportedly afraid. The appellants denied the accusations and presented alibis.

ISSUE

Whether the guilt of the accused-appellants for the crime of murder was proven beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction. The positive identification by two eyewitnesses, Esmenia and Dionisio Maquiling, who knew the appellants well and saw them under adequate illumination from a petromax lamp, prevails over the appellants’ denial and alibi. The delay in revealing their identities to the police, out of fear, does not impair their credibility, especially when the witnesses are close relatives of the victim whose natural interest is to secure justice. The flight of the appellants immediately after the shooting is a further indication of guilt.
The crime is murder qualified by treachery. The attack was sudden, from behind, and without warning, ensuring the execution of the crime without risk to the assailants. Evident premeditation was also established, as the victim’s prior disclosure about the quarrel and his apprehension demonstrated the appellants’ prior plan. This circumstance was properly considered as a generic aggravating circumstance. The aggravating circumstance of dwelling was also present, as the attack occurred within the immediate premises of the victim’s home. Nighttime, however, was absorbed by treachery. With two aggravating circumstances and no mitigating circumstances, the penalty under the Revised Penal Code would be death. However, due to the abolition of the death penalty under the 1987 Constitution, the penalty is reduced to reclusion perpetua.