G.R. No. 104729 - People vs. Javier y Javelosa

On or about December 3, 1990, in Navotas, Metro Manila, an incident occurred at the Navotas Fishery Port involving several fishermen.
The incident emerged from an altercation between two groups in the port area, particularly following a quarrel between Dennis Garcia and Reynaldo Garcia inside a nearby eatery.

Prior to the incident, Rolando Dadua was with the victim, Eric Abante—a young, 18-year-old fisherman—and two other fishermen (Reynaldo Garcia and Joey) at the fish port premises.
After spending some hours in the vicinity of J & A Kitchenette, a disturbance ensued around 10:00 P.M. when Reynaldo Garcia went into the eatery, leading to an altercation with Dennis Garcia.
Amid the ensuing commotion and dispersal of the group, Eric Abante and Rolando Dadua were left behind while others departed.

Accused-appellant Valtony Javier y Javelosa, a casual employee assigned at the Harbor Operations Division near the Port Security Division (PSD), along with Ponciano Enderina (a self-identified fish port policeman), arrived at the scene shortly after the disturbance began.
According to witness testimony, upon arrival at the scene, the accused approached Rolando Dadua and struck him on the head with his gun.
Following the initial assault on Dadua, Enderina was recorded hitting Eric Abante after which Abante attempted to flee, seeking protection by embracing another person present.
The accused then called out to Abante; upon his approach, the accused kicked and further assaulted him with his gun.

At the Port Security Division headquarters, where Dadua and Abante were taken for treatment, the accused continued his assault even as they were under guard.
In a later confrontation at the PSD headquarters, after a brief interval during which witnesses were present and the area was well-lighted, the accused approached Abante again.
With Abante’s hands raised in surrender and pleading innocence, the accused pointed his gun at his face, declared “I will kill you,” and fired a shot that fatally struck Abante between the eyes.
Additionally, the accused attempted to intimidate and maul Dadua, who was saved by the intervention of another individual present at the headquarters.

Patrolmen from the Navotas Police Station were dispatched that same evening to investigate the shooting, visiting both the scene and the PSD headquarters.
Initial reluctance and uncooperative responses by PSD employees complicated the investigation.
A police line-up was later conducted, during which Rolando Dadua positively identified the accused-appellant as the assailant responsible for the shooting and physical assault.
Other witnesses, notably Bienvenido Cruz, corroborated aspects of the incident, providing details such as distinct verbal threats ("Papatayin kita" and descriptions of the sequence of assaults), which contributed to the identification process.

An Information charging the accused with murder was filed on December 6, 1990, before the Regional Trial Court of Malabon.
During arraignment, the accused pleaded not guilty, and the trial primarily relied on the detailed eyewitness testimony of Rolando Dadua along with supporting testimonies from other witnesses.
The trial court rendered a judgment on January 17, 1992, convicting the accused of murder, sentencing him to reclusion perpetua, and ordering various indemnities and damages payable to the victim’s heirs.

Central question: Whether the accused-appellant, Valtony Javier y Javelosa, was correctly and reliably identified as the killer by the eyewitness, Rolando Dadua.
Consideration of the accuracy of the eyewitness identification procedure during the initial event and subsequent police line-up.

Whether the trial court erred in giving full credence to the prosecution’s narrative, particularly the extensive eyewitness testimony, while discounting or inadequately addressing the defense’s version, including the alibi.
Assessment of whether the accused’s alibi and explanations regarding his movements were properly scrutinized against the evidences of his presence in the vicinity.

Despite the defense’s contention that the crime might not have been murder due to the alleged absence of qualifying circumstances such as treachery or premeditation, the issue raised was whether the killing was indeed characterized by treachery.
Evaluation of whether the circumstances—such as the victim’s vulnerable state, close-range shooting, and the assailant’s conduct—justified a conviction for murder rather than a lesser offense.