Case Digest (G.R. No. L-16491)
Facts:
People of the Philippines charged Simeon Paulin, Matias Poroc, Gregorio Magaboyboy, and Manuel Yongco before the Court of First Instance of Misamis Occidental with murder. The trial court found all four accused guilty based on the prosecution’s direct, corroborating, and circumstantial evidence, and it convicted them, imposing twenty (20) years of reclusion temporal for each and ordering indemnification to the victim’s heirs.
On appeal, the accused mainly relied on alibi and unsuccessfully attacked the prosecution witnesses’ credibility. The appellate court affirmed the conviction but modified the principal penalty.
Issues:
- Whether the alibi of Simeon Paulin could overcome the prosecution’s positive identification of him.
- Whether the alibi of Manuel Yongco deserved credence in light of the circumstances shown by the record.
- What penalty should be imposed on each appellant for murder under the Revised Penal Code in the absence of mitigating or aggravating circumstances.
Ruling:
The Court held that the alibi of Simeon Paulin could not prevail over the prosecution witnesses’ positive identification of him and his co-appellants.
The Court also ruled that the alibi of Manuel Yongco could not be credited, considering that he had known Capistrano Lacua only two days before, which made it difficult to believe that Lacua would entrust to Yongco the tasks of gathering nipa and making shingles. With no mitigating or aggravating circumstance, the Court imposed, for each appellant, the medium period of reclusion perpetua pursuant to Article 240 of the Revised Penal Code.
Ratio:
The Court gave controlling weight to the prosecution evidence that positively established the identities of the accused as the perpetrators of the crime. In that context, mere alibi did not raise reasonable doubt as to the accused’s participation.
As to Manuel Yongco, the Court found the alibi inconsistent with the circumstances testified to in the record, particularly the brief time he had known Capistrano Lacua, which undermined the plausibility of the defense version. Because the record showed neither mitigating nor aggravating circumstances, the Court applied the statutory rule on the proper period of the penalty.
Doctrine:
- Alibi cannot prevail over positive identification by credible prosecution witnesses.
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