Facts:

Vladimir Canuzo y Landicho was charged with the murder of Oscar Ulitin, who was shot on August 12, 1991, in front of a store owned by Virgilio Palo in Berinayan, Laurel, Batangas. The incident occurred around 1:00 PM when the victim was seated with crossed legs in front of the store. The prosecution's key witness, Ignacio Manalo, testified that he witnessed Canuzo shoot Ulitin. Manalo, who was 77 years old at the time, stated that he heard six gunshots during the incident. He described how Canuzo appeared suddenly and shot Ulitin, and when Vicente Palo attempted to wrest the gun from Canuzo, the latter managed to retain possession and fled the scene.

The defense argued that Manalo's testimony was not credible, citing discrepancies with the medico-legal report, which indicated that the fatal wounds were frontal. They also attempted to discredit Manalo's presence at the scene by presenting Virgilio Palo, who claimed he was not in the store during the shooting. The defense further contended that the absence of corroborating witnesses and the failure of Manalo to come forward during the police investigation undermined the prosecution's case.

In contrast, the prosecution maintained that the positive identification of Canuzo by Manalo was sufficient for conviction, regardless of the number of witnesses. The trial court found Manalo's testimony credible and noted that the defense's arguments did not sufficiently discredit it.

Legal Issues:

  1. Whether the testimony of a single eyewitness is sufficient for conviction in a murder case.
  2. Whether the trial court erred in its assessment of witness credibility and the weight of evidence presented by the defense.
  3. The implications of the presence of gunpowder residue on the accused's hands in relation to his guilt.

Arguments:

  • Prosecution:

    • The prosecution argued that the testimony of Ignacio Manalo, as the sole eyewitness, was credible and sufficient for conviction. They emphasized that the trial court's assessment of witness credibility should not be disturbed unless there is clear abuse of discretion. The prosecution also pointed out that the presence of gunpowder residue on Canuzo's hands further implicated him in the crime.

  • Defense:

    • The defense contended that the prosecution's case was weak due to the lack of corroborating witnesses and the alleged inconsistencies in Manalo's testimony. They argued that the medico-legal report contradicted Manalo's account of the shooting. The defense also claimed that the absence of Manalo during the initial police investigation indicated a lack of reliability in his testimony.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding Canuzo guilty of murder and imposing the penalty of reclusion perpetua. The court held that the testimony of a single credible witness is sufficient for conviction, as long as it is positive and consistent. The court found no reason to doubt Manalo's credibility, noting his age and lack of motive to fabricate his testimony.

The court also addressed the defense's arguments regarding the medico-legal report, stating that the nature of the attack—whether frontal or from behind—was immaterial, as the shooting was sudden and left the victim with no opportunity to defend himself. The court further dismissed the defense's attempt to discredit Manalo's presence at the scene, emphasizing that Virgilio Palo's testimony was unreliable since he was not present during the shooting.

The court concluded that the presence of gunpowder residue on Canuzo's hands, along with his flight from the scene, indicated his guilt rather than fear for his life. The court reiterated that the trial court's findings on witness credibility and the weight of evidence are generally respected unless there is a clear showing of error.

Significant Legal Principles Established:

  1. The testimony of a single credible witness can be sufficient for conviction in a criminal case, provided it is positive and consistent.
  2. The assessment of witness credibility is primarily within the trial court's discretion and should not be disturbed without clear evidence of abuse.
  3. The presence of gunpowder residue on a suspect's hands can serve as significant evidence of involvement in a shooting incident.