Facts:

• The case involves People of the Philippines vs. Rolando Tamayo, Julio Tamayo, Florencio Patalinghug, Jr., and Natividad Tamayo.
• The accused were charged with double murder in the Regional Trial Court of the Seventh Judicial Region, Branch 62, Oslob, Cebu.
• The information was filed on November 29, 1994, regarding the murder of Leodegario Fuentes and his son Renante Fuentes on October 25, 1994.
• Lilia Fuentes, the wife and mother of the victims, testified that the accused entered their home and shot her husband and son.
• Lilia reported the crime to the police two days after the incident.
• The trial court convicted Rolando Tamayo, Julio Tamayo, and Florencio Patalinghug, Jr. of double murder on September 15, 1998, sentencing them to reclusion perpetua.
• Natividad Tamayo was acquitted due to insufficient evidence.
• Florencio Patalinghug, Jr. appealed the decision, questioning the credibility of the eyewitness and the evidence against him.

Issue:

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Ruling:

• The Supreme Court affirmed the trial court's decision, supporting the credibility of Lilia Fuentes' testimony.
• The defense of alibi was deemed insufficient as it did not prove it was physically impossible for Patalinghug to be at the crime scene.
• While conspiracy was not sufficiently established, Patalinghug was found to be an accomplice to the crime.
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Ratio:

• The Supreme Court highlighted the reliability of Lilia Fuentes' eyewitness testimony, stating that minor inconsistencies did not detract from her overall credibility.
• The defense of alibi was inadequate as it failed to show that Patalinghug could not have been at the crime...continue reading