Facts:

The case involves Jose Dayson, the accused-appellant, who was charged with murder in an information dated February 1, 1991. The incident occurred on May 18, 1990, at approximately 9:00 PM in Barangay Tinapian, Municipality of Manito, Province of Albay, Philippines. The charge stemmed from the fatal shooting of Pedro Trilles, who was attacked by Dayson and two unidentified accomplices. The information alleged that the attack was premeditated and executed with treachery, resulting in a gunshot wound to Trilles' skull, which caused his death.

The Regional Trial Court, presided over by Judge Antonio A. Arcangel, found Dayson guilty beyond reasonable doubt of murder, emphasizing that the victim was in a vulnerable state due to intoxication and had no chance to defend himself. The court noted the aggravating circumstances of the crime being committed in the victim's dwelling at night and by a group of armed men. Dayson was sentenced to reclusion perpetua and ordered to p...

Facts:

Incident Details

• Date and Time: On or about 18 May 1990, at around 9:00 PM.
• Location: Barangay Tinapian, Municipality of Manito, Province of Albay, Philippines.
• Victim: Pedro Trilles, who was killed by a gunshot wound to the skull.
• Accused: Jose Dayson, a member of the Civilian Armed Forces Guerilla Unit (CAFGU), along with two unidentified accomplices.

Witness Testimonies

• Nieves Trilles (Widow of the Victim):

  • She was with her husband in their well-lit hut when Dayson entered through the doorless kitchen.
  • Dayson shot Pedro Trilles at close range, killing him instantly.
  • She recognized Dayson, whom she had known for almost ten years.
  • She saw Dayson leave the house and join two other unidentified individuals outside.
  • She reported the incident to the authorities the following day.

• Elena T. Alcera (Sister of the Victim and Barangay Captain):

  • She was informed of the incident by Nieves at around 6:00 AM on 19 May 1990.
  • She and her kagawads went to the scene and found Pedro Trilles' body with a gunshot wound to the skull.
  • The body was taken to Manito town for an autopsy performed by Dr. Napoleon Se.

Defense's Alibi

• Jose Dayson:

  • Claimed he was on guard duty at the CAFGU detachment in Manumbalay, about 3 kilometers away from Tinapian, between 6:00 PM and 10:00 PM on the day of the incident.
  • He was relieved by Marcelo Perol at around 10:00 PM and spent the night at the detachment's bunkhouse.
  • CAFGU soldiers could only carry firearms while on guard duty or during important missions.

• Marcelo Perol and Millallos (Defense Witnesses):

  • Perol corroborated Dayson's alibi, stating he relieved Dayson at 10:00 PM.
  • Millallos testified that the detachment was informed of the shooting incident on 19 May 1990 but no names were mentioned, and no entry was made in the blotter.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Alibi Defense:

   • The Court reiterated that for alibi to be credible, the accused must prove (a) his presence at another place at the time of the crime and (b) that it was physically impossible for him to be at the scene.
   • Dayson failed to convincingly establish these elements. The distance between the CAFGU detachment and the victim's house could be traversed in 20 minutes, and the detachment's perimeter was not closely monitored.
   • The positive identification by Nieves Trilles, who knew Dayson for almost ten years, outweighed the alibi defense.

2. Aggravating Circumstances:

   • Dwelling: The crime was committed in the victim's house without provocation, which is an aggravating circumstance.
   • Treachery: The victim was "almost unconscious and very drunk," making him unable to defend himself, which qualifies the killing as treacherous.
   • Nighttime and Commission by a Band: The Court found these circumstances not sufficiently established. Nighttime is only aggravating if specifically sought, and "by a band" requires more than three armed individuals acting together.

3. Motive:

   • The Court ruled that motive is not an essential element of the crime, especially when the accused is positively identified. The lack of motive does not affect the conviction.

4. Witness Credibility:

   • The trial court found Nieves Trilles' testimony to be "straightforward, convincing, and not destroyed by cross-examination." The Court deferred to the trial court's assessment of witness credibility.

5. Penalty:

   • The presence of the aggravating circumstances of dwelling and treachery justified the imposition of reclusion perpetua.

Conclusion:

The Supreme Court upheld the trial court's decision, affirming Jose Dayson's guilt for the murder of Pedro Trilles. The Court discarded the trial court's appreciation of nighttime and commission by a band as aggravating circumstances but maintained the penalty of reclusion perpetua based on the presence of dwelling and treachery.