Facts:

• Defendants: Juan Brioso and Mariano Taeza.
• Charge: Murder of Silvino Daria.
• Date: December 23, 1966.
• Location: Municipality of Tayum, Province of Abra, Philippines.
• Description: Daria was making rope in his house between 8 and 9 PM when he was shot through the bamboo wall by the defendants, witnessed by his wife Susana Tumalip and niece Cecilia Bernal.
• Motive: Taeza’s courtship of Daria’s daughter Angelita was disapproved.
• Trial Court: Court of First Instance of Abra found both defendants guilty of murder.
• Sentence: Life imprisonment and indemnity of P6,000.00.
• Appeal: Defendants questioned the reliability of witness testimonies and the rejection of an affidavit clearing Taeza.

Issue:

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Ruling:

1. Witness Testimony: The Supreme Court found no material discrepancies in Cecilia Bernal’s testimony and upheld the lower court’s reliance on her identification of the accused.
2. Affidavit Rejection: The Supreme Court ruled that the affidavit of Antonio Daria had no probative value and upheld the lower court’s decision to disregard it.
3. Guilt Finding: The Supreme Court affirmed the lower ...(Unlock)

Ratio:

• Credibility of Testimony: The Supreme Court held that Cecilia Bernal’s testimony was credible and consistent on material points. Minor inconsistencies did not undermine her identification of the accused, aided by bright moonlight and her familiarity with them.
• Affidavit Issues: The affidavit of Antonio Daria was dismissed as it lacked the necessary seal, was not identified by the affiant, and deprived the prosecution of cross-examination.
• Weak Defense: The defense of alibi was deemed weak and uncorroborated, failing to establish physical impossibility for the accused’s presence at the crime scene.
• Qualified Killing: The killing was qualified by treachery, as the victim was caught off-guard an...continue reading