GR 143819; (January, 2002) (Digest)
G.R. No. 143819 . January 29, 2002.
PEOPLE OF THE PHILIPPINES, appellee, vs. GERRY CUENCA y MEDRANO, JACKSON CUENCA (at large), CRISANTO AGON y MAGPANTAY, and BERNIE AGON (at large), accused, GERRY CUENCA y MEDRANO and CRISANTO AGON y MAGPANTAY, appellants.
FACTS
On the evening of February 14, 1998, in Lipa City, Marcial Morillo heard a commotion outside his house. Investigating, he witnessed four men—appellants Gerry Cuenca and Crisanto Agon, along with Jackson Cuenca and Bernie Agon—mauling Wilfredo Castillo. Morillo, who knew all individuals involved as neighbors, observed from about ten meters away under illumination from a nearby electric bulb and moonlight. He saw the Agons holding Castillo’s hands while the Cuencas beat him with pieces of wood until he lost consciousness. The four then carried Castillo’s body towards a highway. The following day, Castillo’s body was found in a well with multiple stab wounds and injuries.
Appellants Gerry Cuenca and Crisanto Agon were charged with Murder. They pleaded not guilty, while their co-accused remained at large. The prosecution primarily relied on the eyewitness account of Marcial Morillo. The defense consisted of alibi and denial, claiming they were elsewhere during the incident. The Regional Trial Court convicted appellants as principals by direct participation, sentencing them to reclusion perpetua.
ISSUE
Was the testimony of a single eyewitness, Marcial Morillo, sufficient to prove the guilt of appellants beyond reasonable doubt for the crime of Murder?
RULING
Yes. The Supreme Court affirmed the conviction, holding that the testimony of a single eyewitness, if credible and positive, is sufficient to support a conviction. The Court emphasized that truth is established by the quality, not the quantity, of evidence. Morillo’s testimony was found credible, consistent, and unwavering. He had a clear view of the incident, recognized the appellants as longtime neighbors, and his narration of events was detailed and logical. The Court found no ill motive for him to falsely testify. The defense of alibi and denial could not prevail over Morillo’s positive identification. The presence of conspiracy was established by the appellants’ collective actions in assaulting the victim and disposing of his body. The qualifying circumstance of treachery was correctly appreciated as the attack was sudden and rendered the victim defenseless. The Court modified the damages awarded but sustained the penalty of reclusion perpetua. The appeal was dismissed.