In People v. Galano, the Supreme Court affirmed the conviction of three appellants for murder, underscoring the crucial role of eyewitness testimony and the appreciation of treachery in violent crimes. The Court emphasized that a single, credible eyewitness account can suffice for conviction, especially when the testimony is consistent and sincere. This case reinforces the principle that the sudden and unexpected nature of an attack, which ensures the offender’s safety while depriving the victim of any chance to defend themselves, constitutes treachery, thereby qualifying the killing as murder.

When Strangers Attack: Can Justice Prevail Based on a Survivor’s Account?

The case revolves around the tragic events of September 8, 1990, when Virgilio and Leonardo Torres were attacked while waiting for a ride. Leonardo died from his injuries, while Virgilio survived to recount the events. The prosecution hinged on Virgilio’s testimony, identifying Benjamin Galano as the one who stabbed them, with Brigido Tripoli and Romulo Sta. Iglesia holding them down. The defense argued that Virgilio’s testimony was unreliable, and that Benjamin, being right-handed, could not have inflicted the wounds as described. This raised critical questions about witness credibility, the sufficiency of evidence, and the proper application of the elements of murder, particularly treachery.

The Supreme Court meticulously analyzed the appellants’ claims, beginning with the challenge to Virgilio Torres’s credibility. The defense argued that the witness could not have accurately identified the assailants due to the fast-paced nature of the event and the insufficient lighting. However, the Court found this argument unconvincing, reiterating the principle that illumination from a lamp post can be sufficient for identification purposes. Furthermore, the Court acknowledged that individuals react differently under emotional stress, and Virgilio’s vivid recollection of the events was not surprising, given the shocking nature of the attack. This is consistent with established jurisprudence, as the Supreme Court noted in People v. Ranido, 288 SCRA 369, 379 (1998), stating that “people react differently under emotional stress and there is no standard form of behavior when one is confronted by a shocking incident.”

Moreover, the defense contended that Virgilio’s testimony was uncorroborated. However, the Court emphasized that the testimony of a single, credible eyewitness can be sufficient to establish guilt beyond a reasonable doubt. The Court has consistently held that witnesses are to be weighed, not numbered, and a conviction can be based on the testimony of a single witness if found positive and credible. The court, in People v. Bundang, 272 SCRA 641, 651 (1997), citing People v. Camat, 256 SCRA 52, 63 (1996), stated that “the sole testimony of an eyewitness, if found convincing and trustworthy by the court, is sufficient to support a finding of guilt beyond reasonable doubt.” In this case, the Court found Virgilio’s testimony convincing and trustworthy, noting the absence of any ill motive on his part to testify against the appellants.

The appellants also raised the defense of alibi, claiming they were elsewhere at the time of the crime. However, the Court dismissed this defense, noting that the appellants had not only admitted to being within the vicinity of the crime but also failed to prove the physical impossibility of their presence at the scene. The Supreme Court has consistently held that for alibi to prosper, the accused must demonstrate both their absence from the crime scene and the physical impossibility of their presence at the time of the offense. “Positive identification, where categorical and consistent and without any showing of ill motive on the part of the eyewitness testifying on the matter, prevails over alibi and denial which if not substantiated by clear and convincing evidence are negative and self-serving evidence undeserving weight in law,” as stated in People v. Enriquez, 292 SCRA 656, 661 (1998).

A crucial aspect of the case was the determination of whether treachery attended the killing of Leonardo Torres. The appellants argued that the victim could have used his lower extremities to defend himself, even with his hands held. However, the Court disagreed, emphasizing that the suddenness and unexpected nature of the attack, coupled with the restraint imposed by the other appellants, deprived Leonardo of any real opportunity to defend himself. The Revised Penal Code defines treachery in Article 14 (16) as when “the offender commits any of the crimes against persons employing means, methods or forms in the execution thereof, which tend directly and specially to insure its execution, without risk to himself arising from defense which the offended party might make.” The Court concluded that the attack was deliberate and without warning, affording the victim no chance to resist or escape, thus establishing treachery.

Furthermore, the Court addressed the issue of motive, noting that while motive is not an essential element of murder, it becomes relevant when the evidence is circumstantial or inconclusive. In this case, however, the Court found that the positive identification of the appellants by Virgilio Torres rendered the issue of motive immaterial. The court, in People v. Astorga, 283 SCRA 420, 433 (1997), stated that “motive becomes material only when the evidence is circumstantial or inconclusive, and there is some doubt on whether a crime has been committed or whether the accused has committed it. Indeed, motive is totally irrelevant when ample direct evidence sustains the culpability of the accused beyond reasonable doubt.”

Finally, the Court upheld the trial court’s imposition of reclusion perpetua, the appropriate penalty for murder under Article 248 of the Revised Penal Code at the time the offense was committed. The Court also ordered the appellants to jointly and severally indemnify the heirs of Leonardo Torres in the amount of P50,000.00, consistent with prevailing jurisprudence.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution presented sufficient evidence to convict the accused of murder, focusing on the credibility of the eyewitness and the presence of treachery. The court assessed the reliability of the witness’s testimony and whether the attack was executed in a manner that ensured the victim’s inability to defend himself.
Is a single eyewitness account enough for a conviction?	Yes, the Supreme Court affirmed that a conviction can be based on the testimony of a single, credible eyewitness. The court emphasized that the quality of the testimony is more important than the number of witnesses, provided that the testimony is convincing and trustworthy.
What constitutes treachery in murder cases?	Treachery exists when the offender employs means to ensure the execution of the crime without risk to themselves, arising from the defense the offended party might make. The attack must be deliberate and without warning, affording the victim no chance to resist or escape.
How does alibi factor into the court’s decision?	For alibi to be considered valid, the accused must prove they were not only absent from the crime scene but that it was physically impossible for them to be present. The court found the appellants’ alibi unconvincing as they admitted to being in the vicinity and failed to prove physical impossibility.
Is motive necessary for a murder conviction?	Motive is not an essential element of murder, but it becomes relevant when the evidence is circumstantial or inconclusive. In this case, the Court found the positive identification of the appellants by the eyewitness rendered the issue of motive immaterial.
What was the penalty imposed in this case?	The Supreme Court affirmed the trial court’s decision to impose the penalty of reclusion perpetua on the appellants. They were also ordered to jointly and severally indemnify the heirs of the victim in the amount of P50,000.00.
What if the eyewitness testimony is inconsistent?	If the eyewitness testimony contains significant inconsistencies or is otherwise unreliable, the court may not rely on it for a conviction. The credibility of the witness is crucial, and any doubts may be resolved in favor of the accused.
Can a right-handed person commit a crime described as being done by a left-handed person?	The court addressed this issue by noting that there was nothing to suggest that the right-handed appellant could not use his left hand to inflict the wounds. The mere fact that someone is predominantly right-handed does not preclude them from using their left hand.

People v. Galano serves as a testament to the importance of eyewitness testimony and the proper application of legal principles in ensuring justice for victims of violent crime. The Supreme Court’s decision reinforces the idea that a single, credible witness can be sufficient for a conviction, and that treachery, when present, elevates a killing to the crime of murder.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Galano, G.R. No. 111806, March 09, 2000