People v. Salazar
REITERATIONFacts
The Antecedents: On January 30, 1970, at around eleven o'clock in the evening, Fe Reyes-Comea and her husband, Agapito Comea, the barrio captain, were making copra in a kiln illuminated by a lamp. While Agapito was feeding the furnace, Fe heard footsteps and, upon turning, saw Adriano Salazar aiming a gun at her husband's back. Salazar fired one shot, and Pablito Masongsong was behind Salazar. After the shot, Salazar remarked, "Tayo na pare at patay na." Agapito sustained a mortal wound on his back, and the cause of death was shock due to hemorrhage. The killing was allegedly provoked by Agapito's role as the principal prosecution witness in a theft case against Salazar's wife and relatives. Procedural History: Based on Fe Reyes-Comea's sworn statement, a complaint for murder was filed against Salazar and Masongsong. Salazar waived preliminary investigation. The Fiscal filed an information for murder. The Circuit Criminal Court at Lucena City convicted Salazar of murder, sentencing him to reclusion perpetua and ordering him to indemnify the heirs of Agapito Comea. Masongsong was acquitted due to insufficiency of evidence. Salazar appealed. The Petition: Appellant Salazar contended that Fe Reyes-Comea might have been mistaken in her identification, that the trial court erred in not considering the victim had many enemies, and that Salazar's alibi should have been given credence. The crucial issue was the sufficiency of Fe Comea's testimony to convict Salazar.
Issue(s)
Whether Fe Reyes-Comea's testimony as the sole eyewitness is sufficient to convict appellant Adriano Salazar. Whether the trial court erred in not giving credence to Salazar's alibi. Whether the trial court erred in not considering that the victim had many enemies.
Ruling
The Supreme Court affirmed the trial court's judgment, finding Salazar guilty of murder and sentencing him to reclusion perpetua. The Court ordered him to indemnify the heirs of Agapito Comea in the sum of P12,000.00 and to pay the costs.
Ratio Decidendi
On the sufficiency of Fe Reyes-Comea's testimony: The Court found Fe Reyes-Comea's testimony to be credible, clear, positive, and devoid of artificiality. The opportunity for identification was favorable due to the illuminated kiln and level ground. Salazar was identified at a distance of about three arms' length. The Court noted that Fe had known Salazar for a long time and that Masongsong was defeated by her husband in an election, making the possibility of an honest mistake in identification remote. Furthermore, Fe immediately identified Salazar as the gunman to the police authorities and in the preliminary examination before the municipal judge, which precluded any possibility of bad faith or fabrication. The Court reiterated the principle that the testimony of a single witness may be sufficient to produce conviction if it appears to be trustworthy and reliable, citing several cases. On Salazar's alibi: The Court gave no credence to Salazar's alibi, which was corroborated by his wife and two other individuals. The Court found that Salazar's house was only about five hundred meters away from the scene of the crime, making it possible for him to have gone to the scene and returned promptly. The Court emphasized that for an alibi to be credible, the accused must establish that it was impossible for him to have been at the place of the crime at the time of its commission, citing People vs. Resayaga and People vs. Lumantas. Since Salazar's alibi did not meet this standard and was contradicted by positive identification, it could not prevail. On the victim having many enemies: The Court implicitly addressed this by focusing on the positive identification and the credibility of the eyewitness. While the fact that the victim had enemies was raised as a contention, the Court's affirmation of the conviction based on the eyewitness testimony indicates that this factor did not create reasonable doubt sufficient to overturn the conviction, especially given the direct identification of Salazar as the perpetrator.
Main Doctrine
The positive identification of the accused by a credible eyewitness, even if the latter is the sole witness, is sufficient to sustain a conviction, especially when the accused's alibi is weak and uncorroborated by independent evidence, and the eyewitness's identification is made promptly after the commission of the crime.