G.R. No. 122766 ; June 20, 2003
PEOPLE OF THE PHILIPPINES, Appellee, vs. FELIPE ESPONILLA and SAMSON ESPONILLA, Appellants.

FACTS

Appellants Felipe and Samson Esponilla were charged with the murder of Jose Eumag. The prosecution’s case, primarily through the eyewitness testimony of the victim’s wife, Enriqueta Eumag, established that on June 28, 1991, while Jose was plowing his field and Enriqueta was nearby, two gunshots rang out. Enriqueta saw Jose fall and, upon looking, saw the appellants standing about seven meters away, each holding a firearm aimed at her husband. The appellants then fled. The incident stemmed from previous animosity, as Jose had testified against a cousin of the appellants in a prior case, and the appellants were already on trial for the frustrated murder of Jose from a 1989 shooting. The medical examination confirmed Jose died from gunshot wounds.
The appellants interposed the defenses of denial and alibi. Felipe claimed he was at his farm, while Samson asserted he was in a different barangay at the time of the shooting. They alleged that Enriqueta’s testimony was motivated by revenge due to the pending frustrated murder case and the earlier death of their cousin. The trial court convicted them of murder qualified by treachery and sentenced each to reclusion perpetua.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellants beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found the positive identification by eyewitness Enriqueta Eumag to be credible, convincing, and consistent. Her proximity to the event and her familiarity with the appellants, whom she had known for a long time, rendered her testimony highly reliable. The Court ruled that her testimony alone, if credible, is sufficient to sustain a conviction. The defense of alibi was properly rejected as it was not physically impossible for the appellants to have been at the crime scene. The Court also found the element of treachery present, as the attack was sudden and from behind, giving the victim no opportunity to defend himself.
However, the Court modified the damages awarded. It upheld the award of civil indemnity and moral damages but deleted the award for loss of earning capacity due to the lack of sufficient proof of the victim’s net income. The Court instead awarded temperate damages for the wake and funeral expenses, which were incurred but not receipted. The appellants were thus sentenced to reclusion perpetua and ordered to pay, jointly and severally, civil indemnity, moral damages, and temperate damages to the heirs of the victim.