G.R. No. 76952 - People vs. Sabado

The incident occurred on December 1, 1983, at Sitio Bagsit Bo. Unzad, Villasis, Pangasinan during a rice harvesting activity.
The accused, Juanito Sabado, was present along with other individuals including Pedro Delfin, Ceferino Natura, Emiliano Natura (the victim), and Monico Natura (the victim’s father).

After participating in the harvest, Emiliano Natura, Pedro Delfin, and Juanito Sabado retreated to a tent where they rested; the tent was lit by a single kerosene lamp.
Around 10:00 o’clock in the evening, Ceferino Natura and Pedro Delfin left the tent to fetch cigarettes, exiting through the open eastern side.
Shortly after their departure, both witnesses heard a shot coming from the tent.
When they returned, they observed Juanito Sabado standing near a lying Emiliano Natura in a stooping position, firing successive shots with a gun.
Immediately, Sabado was seen fleeing the tent through the open western side.

The witnesses, stricken with shock, informed Monico Natura, leading to the discovery of Emiliano Natura’s lifeless body, bearing multiple gunshot wounds.
Monico Natura later incurred expenses for the coffin, tomb, embalming, funeral services, and related expenses totaling P8,560.00.
Due to the late hour and the unavailability of transportation, the incident was reported to the authorities only the following morning.

In his testimony, the accused claimed that he and Emiliano Natura were sleeping side by side in the tent until awoken by a flashlight beam.
He alleged that two patrolmen, Ruben Pituc and Romeo Imus, were responsible for shooting the victim after they had emerged from behind other individuals present.
Despite his account, he later encountered these patrolmen at the Villasis Municipal Hall, contradicting his narrative of fear and avoidance.
Apprehension followed when a warrant for his arrest was communicated to him, leading him to eventually surrender to local authorities under the accompaniment of Barangay Captain Montero.

Prosecution witnesses Pedro Delfin and Ceferino Natura provided clear, direct, and consistent testimonies identifying Juanito Sabado as the shooter.
Their testimonies detailed that the victim was shot while lying down, leaving him defenseless and incapable of resistance.
In contrast, the defense sought to attribute the crime to the patrolmen, supported by testimonies from Barangay Captain Montero and Councilman Rabanzo; however, these were undermined by inconsistencies and conflicting circumstantial details.
The physical evidence, including the arrangement of the tent and the manner of the shooting, corroborated the prosecution’s narrative over the defendant’s version.

Whether the testimonies of prosecution witnesses, Pedro Delfin and Ceferino Natura—despite their personal connections to the victim—were tainted by bias or improper motive.
Whether their positive and consistent identification of the accused as the gunman should be given full evidentiary weight.

Whether the accused’s version, which implicated Patrolmen Pituc and Imus as the shooters, holds credibility given his later actions and inconsistent account.
Whether the conflicting accounts between the prosecution and defense create a reasonable doubt as to the accused’s guilt.

Whether the defendant’s claim of fear leading to a delayed report is credible in light of his subsequent visit to the Villasis Municipal Hall.
Whether the inconsistencies in his testimony and failure to act immediately undermine his version of events.

Whether the circumstances of the shooting—specifically targeting a defenseless victim lying down—constitute treachery.
Whether the elements of treachery, such as deliberate choice of means to ensure the offender’s safety, are clearly met in the instance at hand.