People vs. Alunan

G.R. No. 88822 (July 15, 1996)

Facts:

On April 25, 1982, at approximately 6:00 p.m., an incident occurred at the Orig Restaurant in Bacolod City, where the victim, Ronaldo Javier, was socializing with friends. As the evening progressed, two men, later identified as Nelson Alunan (the appellant) and Alejandro Tuvilla, entered the restaurant and ordered drinks. After consuming their beverages, they moved to a table closer to Ronaldo and his group.

Witness Angelita Noquera Flores, a waitress at the restaurant, observed the two men and engaged in a brief conversation with them. After some time, Alunan and Tuvilla went to the comfort room, and upon returning, they approached Ronaldo's table. Tuvilla suddenly attacked Ronaldo from behind, holding him by the neck and stabbing him multiple times in the chest. Alunan assisted Tuvilla in restraining Ronaldo, and both continued to stab him even after he fell to the ground.

Following the attack, the assailants fled the scene, while Angelita called for help. Ronaldo was subsequently taken to the hospital but was pronounced dead on arrival. The prosecution charged Alunan and Tuvilla with murder, while another accused, Larry Tillo, was acquitted due to insufficient evidence.

Legal Issues:

1. Whether the trial court erred in giving credence to the testimony of the prosecution's main witness, Angelita Flores.
2. Whether the trial court's assessment of the credibility of the accused's testimonies was flawed.
3. Whether the trial court committed inconsistencies in its findings regarding conspiracy among the accused.

Arguments:

• For the Prosecution: The prosecution argued that Angelita Flores provided clear and unequivocal testimony identifying Alunan and Tuvilla as the perpetrators of the crime. Her account was consistent and corroborated by the circumstances surrounding the incident, including her immediate reaction to call for help after witnessing the stabbing.

• For the Defense: Alunan contended that the trial court erred in relying on Flores' testimony, claiming it was filled with inconsistencies and improbabilities. He also argued that the trial judge, who did not preside over the entire trial, could not adequately assess the credibility of the witnesses. Furthermore, he questioned the existence of conspiracy, especially in light of Tillo's acquittal.

Court's Decision and Legal Reasoning:

The court affirmed the lower court's decision, emphasizing the following points:

1. Credibility of Witnesses: The court noted that the trial judge's assessment of witness credibility is generally binding. Despite the judge-designate not being present during the entire trial, the decision was supported by the evidence on record. The court found Flores' testimony to be credible, as it was given shortly after the incident and lacked any apparent motive for falsehood.

2. Positive Identification: The court reiterated that the testimony of a single credible witness is sufficient for conviction, especially in murder cases. Flores' identification of Alunan and Tuvilla was direct and clear, and her account was consistent throughout the trial.

3. Denial and Alibi: The court dismissed Alunan's defense of denial as weak, particularly in light of the strong eyewitness testimony against him. The court highlighted that mere denial cannot outweigh positive identification.

4. Conspiracy: The court clarified that the acquittal of Tillo did not negate Alunan's involvement. The existence of conspiracy was not necessary to establish Alunan's guilt, as his identity as one of the assailants was firmly established.

Significant Legal Principles Established:

• The testimony of a single credible witness can suffice for a conviction in murder cases.
• The trial court's assessment of witness credibility is generally upheld unless there are compelling reasons to question it.
• Denial and alibi are weak defenses against positive identification by a credible witness.
• The presence of conspiracy among co-accused is not a prerequisite for establishing the guilt of an individual accused.