G.R. No. L-32163 - People vs. Alonzo

On April 29, 1966, Wilfredo Flores (alias “Willie Flores”) was fatally stabbed in Balanga, Bataan.
The murder occurred in the vicinity of the Orchid Refreshment and the Victory Lumber in the Poblacion of Balanga.
Eyewitness testimony established that during the hours between four and five in the afternoon, four individuals inquired for the victim’s residence and later reappeared at the scene.

Witness Sebastian Estember and his companion observed the four accused—Antonio Alonzo, Renato Hernando, Rolando Gano, and Juan Villosillo—as they actively sought Flores.
After Flores conversed with Estember at Farmacia Reyes, the four accused disappeared, only to reemerge later by ambushing and ganging up on Flores.
It was specifically testified that Antonio Alonzo, as identified by Estember, was the one who stabbed Flores, resulting in immediate death due to blood loss, as confirmed by the autopsy of Dr. Melanio T. Banzon.
The prosecution also emphasized a potential motive linked to a prior altercation where the victim was suspected of having stabbed Rufino Alonzo, the younger brother of the accused Antonio Alonzo.

Each accused presented an alibi intended to prove their absence from the scene of the crime:

Juan Villosillo testified that he was harvesting peanuts in Niyugan from early morning until late evening, supported by witnesses Carmelita Diwa and Eufemia Zabala.
Rolando Gano provided a detailed account of being involved in guarding a bulldozer in Nagwaling and later traveling back to Balanga, recounting observations that placed him at a transportation point near the scene only after the incident was discovered.
Renato Hernando testified that he was at his family farm in Maulang, assisting in farm duties, with his father corroborating this account.
Antonio Alonzo claimed he was in his field at sitio Lupang Tagalog and later sought irrigation assistance, supported by three eyewitnesses who placed him irrigating his field in the early evening.

Despite the multiple alibi testimonies, the defense did not provide substantial or consistent evidence to refute the direct eyewitness identification presented by the prosecution.

The eyewitnesses, including the pivotal testimony of Sebastian Estember, identified the accused as being present together and involved in the crime.
Circumstantial evidence linked the accused not only by opportunity but by an apparent prearranged plan suggesting a common design to commit the killing.

Whether the evidence on record was sufficient to sustain the conviction of the accused for the crime of murder.

The reliability and unanimity of the eyewitness identification versus the defense’s alibi.
The weight of circumstantial evidence pointing to a premeditated, concerted effort to commit the murder.

Whether the failure of the defense counsel to expound a thorough statement of the facts and to counter the prosecution’s narrative constituted reversible error.

Whether the lower court properly rejected the alibi defense despite the presentation of alternative testimonies by the accused.

Whether the lower court correctly inferred and applied the doctrine of conspiracy based on the joint actions and agreement of the accused.

Whether the characterization of the crime as murder (qualified by alevosia) rather than a lesser offense such as homicide was proper under the established facts.