Title
People vs. Alapan
Case
G.R. No. 97285
Decision Date
Jun 16, 1995
Three men accused of murdering Renato Adecer over a love rivalry; eyewitnesses identified Nestor Alapan and Francisco Clavido as accomplices, leading to their conviction despite alibi defenses.
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Case Digest (G.R. No. 97285)

Facts:

Incident Overview:

  • Nestor Alapan and Francisco Clavido, along with Cresente Pija (who remains at large), were accused of murdering 20-year-old Renato Adecer.
  • The incident occurred on February 4, 1990, in San Isidro, Sinacaban, Misamis Occidental.
  • Renato Adecer was courting Annelyn Poledo, who was also being courted by Cresente Pija.

Prosecution’s Version:

  • Renato Adecer and his four friends were walking home after escorting Annelyn Poledo.
  • They were attacked near the market of San Isidro Alto.
  • Cresente Pija hacked Renato on the forehead with a bolo.
  • Nestor Alapan repeatedly stabbed Renato with a hunting knife while Francisco Clavido held the victim, preventing him from defending himself.
  • Renato died from multiple stab and hacking wounds, as confirmed by Dr. Gloria Bongabong.

Eyewitness Testimonies:

  1. Nilo Madronero (13 years old):
    • Saw Pija hack Renato on the forehead, followed by Alapan stabbing the victim while Clavido held him.
  2. Rodrigo Macas (16 years old):
    • Corroborated Madronero’s account, adding that Pija also hacked Renato on the neck.
  3. Vicente Idol (21 years old):
    • Provided additional details, stating that Alapan and Clavido were seated on the left side of the road while Pija was on the right.
    • Renato greeted them, and Pija suddenly attacked him.

Defense’s Version:

  • Alapan and Clavido claimed they were drinking Tanduay Rhum with Pija in the market earlier that day but separated before the incident.
  • They presented witnesses who claimed Pija acted alone.
  • Barangay Captain Mamerto Aganos testified that Pija surrendered the bolo and confessed to killing Renato over a woman.

Issue:

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Ruling:

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Ratio:

  1. Credibility of Witnesses:

    • The trial court’s assessment of witness credibility is given great weight, as it has the opportunity to observe their demeanor and conduct.
    • The prosecution witnesses testified vividly and consistently, with no evidence of improper motive to falsely implicate the appellants.
  2. Alibi Defense:

    • Alibi is a weak defense, especially when the accused are positively identified by credible witnesses.
    • Alapan and Clavido failed to prove they were far enough from the crime scene to be physically incapable of participating in the killing.
  3. Human Behavior in Startling Situations:

    • There is no standard behavioral response to a shocking or frightening event. The witnesses’ immobility during the attack does not render their testimonies incredible.
  4. Participation in the Crime:

    • The prosecution proved beyond reasonable doubt that Alapan and Clavido actively participated in the killing.
    • Alapan repeatedly stabbed the victim, while Clavido held him, ensuring the crime’s success without risk of retaliation.
  5. Scapegoating Pija:

    • The defense’s attempt to pin the entire blame on Pija, who remains at large, is suspicious and unsupported by credible evidence.


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