Facts:

The case involves Rodolfo C. Velasco as the petitioner and the People of the Philippines as the respondent. The events transpired on April 19, 1998, in Dagupan City, Philippines, where Velasco was accused of attempted murder against Frederick Maramba. An Information was filed on April 20, 1998, charging Velasco with the crime, alleging that he, armed with a .45 caliber pistol, shot Maramba, hitting him in the left upper arm. The trial court summarized the prosecution's evidence, which included testimonies from Maramba and Armando Maramba, the driver of the tricycle that Velasco used to flee the scene. The prosecution established that Velasco approached Maramba while he was washing his jeep and fired several shots, hitting him once. The police apprehended Velasco shortly after the incident, recovering the firearm and ammunition from him. Velasco pleaded not guilty during his arraignment and presented an alibi, claiming he was elsewhere at the time of the shooting. The Regi...

Facts:

Incident Summary:
On April 19, 1998, in Dagupan City, petitioner Rodolfo C. Velasco was accused of attempted murder. The prosecution alleged that Velasco, armed with a .45 caliber pistol, approached private complainant Frederick Maramba, who was washing his jeep, and fired multiple shots, hitting Maramba in the left upper arm. Maramba managed to escape, sustaining injuries that required hospitalization.

Prosecution’s Evidence:

1. Frederick Maramba’s Testimony: He identified Velasco as the assailant, stating that Velasco fired multiple shots at him at close range.
2. Armando Maramba’s Testimony: The tricycle driver who transported Velasco to the crime scene testified that Velasco alighted, fired at Maramba, and then fled.
3. Police Evidence: The police recovered Velasco’s firearm, magazines, live ammunition, and spent shells at the crime scene.

Defense’s Evidence:

1. Velasco’s Alibi: He claimed he was in Lingayen, Pangasinan, at the time of the incident and was later arrested by the police while riding a tricycle.
2. Denial: Velasco denied knowing or shooting Maramba, asserting that he was framed.

Trial Court Ruling:
The Regional Trial Court (RTC) found Velasco guilty of attempted murder, sentencing him to four years of prision correccional as a minimum to eight years and one day of prision mayor as a maximum. Velasco was also ordered to pay P2,696.00 in actual damages.

Appellate Court Ruling:
The Court of Appeals affirmed the RTC’s decision, dismissing Velasco’s appeal.

Issue:

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Ruling:

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Ratio:

1. Credibility of Witnesses: The Court upheld the credibility of the prosecution witnesses, Frederick Maramba and Armando Maramba, who positively identified Velasco as the assailant.
2. Weakness of Alibi: Velasco’s alibi was rejected, as it was physically possible for him to be at the crime scene during the incident.
3. Treachery: The Court found that the attack was sudden and unexpected, satisfying the elements of treachery.
4. Attempted Murder: Velasco’s actions constituted attempted murder, as he commenced the crime with intent to kill but failed to complete it due to reasons beyond his control.
5. Penalty: The penalty imposed by the trial court was appropriate under the Revised Penal Code and the Indeterminate Sentence Law.

The Supreme Court emphasized that positive identification by credible witnesses outweighs the defense of alibi and denial. Motive is unnecessary when the identity of the assailant is established. The Court also reiterated that treachery exists when the attack is sudden and unexpected, leaving the victim no opportunity to defend themselves.