G.R. No. 205855 - People vs. Ambatang

On or about October 17, 2002, in Taguig City, Metro Manila, King Rex A. Ambatang was charged with the murder of 60-year-old Ely Vidal.
The accused allegedly committed the crime with intent to kill by wielding a kitchen knife, thereby inflicting fatal stab wounds to Vidal.
The killing was characterized by several qualifying circumstances, including treachery, evident premeditation, abuse of superior strength, as well as aggravating factors such as insult and disregard due to the victim’s age and the nighttime occurrence.

Prosecution witnesses, notably Jennifer Vidal Mateo and barangay tanod Romeo Acaba, testified that they saw Ambatang stabbing Vidal.
Additional evidence indicated Ambatang was seen sharpening a knife in his own residence prior to the incident.
Testimony by the victim’s wife, Carmelita Vidal, revealed that the deceased managed to speak and identify his attacker before succumbing to his injuries.
Post-mortem findings confirmed that stab wounds to the chest were the cause of death.

Ambatang claimed that he was at AMA Computer Learning Center from 3:00 p.m. to 8:00 p.m. on the day of the incident, and that he only arrived home at 9:30 p.m.
He stated that upon hearing commotion from outside, he was initially instructed by his mother and sister to remain indoors with his girlfriend.
An attempt was made to corroborate his alibi by testimonies from his mother and his girlfriend; however, such support was viewed with extreme suspicion as it was provided mainly by close relatives and friends.

In the April 5, 2010 Decision, the Regional Trial Court, Branch 163 of Pasig City found Ambatang guilty of murder and sentenced him to reclusion perpetua along with orders to pay various damages (civil indemnity, actual, moral, and temperate damages).
On appeal, the Court of Appeals, in a July 31, 2012 Decision, upheld the conviction while modifying the award of damages—introducing exemplary damages and deleting temperate damages.
Ambatang subsequently filed a Notice of Appeal, leading to the elevation of the case to the Supreme Court.

The records, including testimonies, transcript of stenographic notes, and physical evidence, were thoroughly reviewed by the Supreme Court.
Ambatang’s appeal hinged on the sufficiency of evidence and the alleged inconsistencies within eyewitness accounts, as well as the credibility of his alibi.
The Court noted that the positive and unequivocal identifications made by key prosecution witnesses were of paramount importance in establishing the guilt of the accused.

Whether the factual findings and the weight given to the eyewitness testimonies by the trial court—and subsequently by the Court of Appeals—established beyond reasonable doubt that Ambatang committed the murder.

Whether minor discrepancies in the testimonies of witnesses such as Jennifer and Acaba affect the overall credibility required to uphold the conviction.
The issue of whether the observed inconsistencies detract materially from the identification of Ambatang as the perpetrator.

Whether Ambatang’s alibi, which was mainly supported by close relatives and friends (and introduced belatedly during testimony), was sufficient to create a reasonable doubt as to his presence at the crime scene.
Whether the defense’s reliance on an alibi that was not as robust or corroborated by impartial witnesses could negate the clear evidentiary findings against him.