Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Francisco Villablanca and Eduardo Villablanca as the accused-appellants. The incident occurred on August 19, 1985, in Pastrana, Leyte, where seventeen-year-old Elizabeth Natanio witnessed the brutal murder of her father, Pedro Natanio. The accused, identified as brothers Francisco and Eduardo Villablanca, along with an unidentified accomplice, were charged with murder in the Regional Trial Court of Palo, Leyte. The information stated that the accused conspired to kill Pedro Natanio, using a long bolo and a handgun, and attacked him while he was made to kneel. Elizabeth testified that she recognized the assailants despite the darkness, as she used a flashlight to illuminate their faces. After the attack, her father was taken to the hospital but succumbed to his injuries shortly after arrival. The trial court found the Villablanca brothers guilty of murder, citing the qualifying circumstances of t...

Facts:

Incident Overview:

• On August 19, 1985, in Pastrana, Leyte, Pedro Natanio was brutally murdered in his home.
• The accused, Francisco Villablanca and Eduardo Villablanca, along with an unidentified person (John Doe), were charged with murder.
• The prosecution alleged that the accused conspired to kill Pedro Natanio using treachery and abuse of superior strength.

Key Witness:

• Elizabeth Natanio, the 17-year-old daughter of Pedro Natanio, witnessed the crime and identified the accused as the perpetrators.
• Elizabeth testified that she, her father, and her 14-year-old brother were sleeping when they were awakened by the sound of their chickens. The accused forcibly entered their home, attacked Pedro, and stabbed him multiple times.

Details of the Attack:

• Francisco Villablanca made Pedro kneel and stabbed him in the abdomen with a samurai, while Eduardo Villablanca pointed a gun at Pedro.
• Elizabeth recognized the accused despite the darkness by using her flashlight.
• After the attack, Pedro was taken to the hospital but died before arrival. The autopsy revealed four stab wounds, with the cause of death being hemorrhage due to multiple stab wounds.

Trial Court Findings:

• The trial court found the accused guilty of murder, citing treachery and abuse of superior strength as qualifying circumstances.
• The court sentenced both accused to reclusion perpetua and ordered them to pay P30,000.00 as indemnity to Pedro Natanio’s heirs.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Credibility of a Single Witness:

   • The testimony of a single witness, if positive and credible, is sufficient to support a conviction, even in murder cases.
   • Elizabeth’s testimony was found to be clear, consistent, and credible, and the trial court’s assessment of her credibility was upheld.

2. Treachery as a Qualifying Circumstance:

   • Treachery was present because the attack was sudden and unexpected, leaving Pedro Natanio no opportunity to defend himself.
   • The Court emphasized that treachery requires the deliberate adoption of means to ensure the victim’s inability to retaliate.

3. Alibi as a Defense:

   • Alibi is the weakest defense and cannot prevail over the positive identification of the accused by a credible witness.
   • The appellants failed to provide clear and convincing evidence to substantiate their alibi.

4. Indemnity and Civil Liability:

   • The Court modified the trial court’s award of indemnity, increasing it to P50,000.00 in accordance with current jurisprudence.
   • The appeal opened the entire case for review, allowing the Court to adjust the civil liability.