Title
People vs. Balacio
Case
G.R. No. 100606
Decision Date
Jun 4, 1993
Appellants convicted of murder for hacking Emeterio Pascua to death in 1978; alibi defense rejected, eyewitness testimony upheld, and civil indemnity increased.

Case Summary (A.C. No. 12719)

Allegations and Charges

The information filed against the appellants charged them with murder, stating that they conspired to kill Emeterio N. Pascua on New Year's Eve by ambushing him and inflicting multiple hack wounds with bolos. The charges highlighted the presence of aggravating circumstances, particularly the nighttime setting, which the appellants allegedly exploited to carry out the crime.

Evidence and Witness Testimony

The prosecution's evidence centered on the testimony of Francisco Iday, a witness who met Pascua before the incident and observed the appellants' suspicious behavior before they attacked Pascua as he exited a store. A post-mortem examination by Dr. Felicisimo C. del Rosario confirmed that Pascua died from hack wounds that inflicted serious damage, including severing his trachea and esophagus.

Appellants' Defense

The appellants contested the prosecution's claims through a dual defense strategy consisting of an alibi and questioning the credibility of the prosecution’s sole eyewitness, Iday. Both appellants asserted that they were at the Asin Hot Spring celebrating New Year's with other companions during the time of the murder.

Analysis of the Alibi Defense

The court found the alibi insufficient due to its proximity to the crime scene, making it physically possible for the appellants to leave the Asin Hot Springs, commit the crime, and return without being detected. The conviction of the appellants was additionally bolstered by the credible, positive identification of them as perpetrators by the eyewitness.

Appellants' Credibility Challenges

The appellants raised doubts about Iday's ability to observe the crime due to alleged obstructions and inadequate lighting. However, the trial court conducted an ocular inspection which concluded that the street lighting on that night was sufficient for visibility, thereby refuting the appellants' argument about the obstructive trees.

Evaluation of Witness Testimony

The trial court also addressed the defense's assertion that Iday’s actions were suspicious. It supported the notion that a reasonable person in Iday's position would indeed remain vigilant upon witnessing the appellants' behavior. Iday's delay in reporting the appellants to authorities was attributed to fear for his safety, which the court deemed credibl

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