People v. Benito
REITERATIONFacts
The Antecedents: On February 4, 1988, at around 7:20 p.m., in Barangay Sonquil, Sta. Barbara, Pangasinan, the accused-appellant Henry Benito went to the house of his mother-in-law, Imelda Albarida, looking for his wife. Angered when told his wife was not there, Benito hit the wall of the hut. Shortly thereafter, Benito encountered the victim, Alberto de la Cruz, who questioned Benito's actions. Without a word, Benito pulled a knife and stabbed the victim in the chest, causing his death. Imelda Albarida witnessed the stabbing from the window. Procedural History: The Regional Trial Court of Dagupan City, Branch 43, found Henry Benito guilty beyond reasonable doubt of murder and sentenced him to suffer the penalty of reclusion perpetua, with actual damages, indemnity, and moral damages. The accused appealed the decision. The Petition: The accused-appellant sought reversal of the trial court's decision, primarily assailing the credibility of the prosecution's sole eyewitness, Imelda Albarida, and arguing that her testimony was inconsistent and insufficient for conviction. He also questioned the trial court's reliance on the statement of Pedro Almagan, who was not presented in court.
Issue(s)
Whether the trial court erred in giving full weight and credence to the testimony of prosecution witness Imelda Albarida. Whether the trial court erred in giving full weight and credence to the statement of Pedro Almagan when he was not presented in court. Whether treachery was present as a qualifying circumstance.
Ruling
The Supreme Court dismissed the appeal and affirmed the trial court's judgment. It upheld the conviction of Henry Benito for murder, sentencing him to reclusion perpetua. The award for moral damages was deleted for lack of factual basis.
Ratio Decidendi
On the credibility of Imelda Albarida's testimony: The Court affirmed the trial court's assessment, holding that appellate courts accord the highest respect to the findings of the trial court on the credibility of witnesses. Imelda Albarida's testimony was found to be clear, unequivocal, and credible, despite the incident occurring at night, due to the illumination from a kerosene lamp and her vantage point from the window, which allowed her to clearly see the assailant's face and physical features. The defense failed to adduce evidence of any ill motive on her part, and her positive and categorical declarations under oath deserved full faith and credence. Proof of motive is not indispensable when the accused has been positively identified by an eyewitness and his participation is established. Minor lapses in a witness's testimony, if any, can even buttress credibility by showing the testimony was not coached or contrived. The testimony of a single credible witness is sufficient for conviction. On the statement of Pedro Almagan: The Court noted that the trial court's reference to Pedro Almagan's statement was merely to explain the prosecution's failure to present him as a witness. The conviction was primarily based on the positive identification by Imelda Albarida, not on Almagan's statement. The appellant's defense of denial cannot prevail over the positive identification by the eyewitness. On the presence of treachery: The Court agreed with the trial court in appreciating treachery as a qualifying circumstance. The appellant surreptitiously and without warning stabbed the victim, who was unarmed and unaware of the impending danger. This sudden and unexpected attack rendered the victim unable to defend himself, thus ensuring the safety of the assailant. Treachery exists when the attack is sudden and unexpected, preventing the victim from retaliating or defending himself, even if the attack is frontal.
Main Doctrine
The positive testimony of a single eyewitness, if credible and consistent, is sufficient to sustain a conviction for murder, even in the absence of proof of motive. Flight of the accused after the incident is indicative of guilt. Treachery is appreciated when the attack is sudden and unexpected, rendering the victim unable to defend himself.