People v. Sabado
REITERATIONFacts
The Antecedents: On January 15, 1993, at 9:00 a.m., in a ricefield in Barangay Sinabaan, Umingan, Pangasinan, Fernando Madelo was harrowing his ricefield while his son, Robinson Madelo, was planting rice. Appellant Norberto Sabado appeared from behind and ordered Fernando to work on an irrigation project. Fernando insisted he had already done his work. Robinson noticed Sabado had a firearm and warned his father, but Fernando dismissed the warning. Sabado, standing and facing northwest, shot Fernando, who was facing southward. Fernando fell and died. Sabado fled the scene. An autopsy revealed the cause of death was internal hemorrhage due to lung injury. Procedural History: The Regional Trial Court (RTC) of Tayug, Pangasinan, convicted Norberto Sabado of murder, qualified by evident premeditation, and sentenced him to reclusion perpetua. The RTC ordered him to indemnify the heirs of Fernando Madelo. The Petition: Sabado appealed the RTC decision, arguing that the trial court erred in giving full faith and credence to the lone witness, Robinson Madelo; in giving weight to Exhibit 'D' regarding Robinson's absence; in finding evident premeditation; and in not giving weight to his theory of self-defense.
Issue(s)
Whether the trial court erred in giving full faith and credence to the testimony of the lone witness, Robinson Madelo. Whether the trial court erred in giving weight to Exhibit 'D' and discrediting Exhibit '1' regarding Robinson Madelo's absence. Whether the offense was attended by the qualifying circumstance of evident premeditation. Whether the trial court erred in not giving weight to the accused-appellant's theory of self-defense.
Ruling
The appeal is denied, and the assailed Decision of the RTC is affirmed. The accused-appellant Norberto Sabado is found guilty beyond reasonable doubt of murder, qualified by evident premeditation, and sentenced to reclusion perpetua.
Ratio Decidendi
On the credibility of the lone prosecution witness: The Court affirmed the trial court's reliance on the credible and positive testimony of Robinson Madelo. The Court found the appellant's narration of facts inconsistent and contradictory. The defense's claim that Jeremias Madelo fired at the appellant while the latter was completely covered by the victim was deemed against natural order and human nature. The victim's son's testimony was corroborated by the medicolegal officer's findings and the autopsy report, which indicated the assailant's position was likely on the victim's right side at a distance of at least one meter, consistent with Robinson's account. The Court reiterated the principle that the testimony of a single witness, if credible and positive, is sufficient for conviction. On the reliance on Exhibit 'D': The Court rejected the appellant's argument regarding the conflicting exhibits on Robinson Madelo's absence. The Court found that a class adviser (Exhibit 'D') is in a better position than a principal to know a student's absence on a particular day. Furthermore, Exhibit 'D' was signed by multiple teachers, lending it more credibility. This exhibit corroborated Robinson's presence at the farm with his father. On evident premeditation: The Court found evident premeditation to be present. The strained relationship between the victim and appellant due to water flow issues, the appellant's possession of a gun when he approached the victim, and the victim's refusal to address the dwindling water supply indicated that the appellant had decided to commit the crime and had taken overt acts to do so. The time lapse between the decision and execution allowed for reflection. On the appellant's theory of self-defense: The Court found the appellant's theory of self-defense to be not credible and strange. The appellant claimed he hid behind the victim to shield himself from Jeremias Madelo, and that Jeremias accidentally shot his brother. However, the appellant's primary assertion was that Jeremias, not he, shot the victim, which contradicts the premise of self-defense, where the accused admits authorship of the killing. The Court found the appellant's version of events, including his inconsistent testimonies and flight, to be unbelievable.
Main Doctrine
The credible and positive testimony of a single witness is sufficient for conviction because truth is established by the quality, not necessarily the quantity, of evidence. Flight of the accused evinces a consciousness of guilt.