Case Summary (G.R. No. 82362)
Petitioner and Respondent
Petitioner/Appellant: Norberto Clores y Coral. Respondent/Appellee: People of the Philippines.
Key Dates (operative factual and lower court dates)
Crime: 24 December 1986 at about 2:00 a.m. Identification and sworn statements given to police: 24 December 1986 (same day). RTC decision: promulgated 7 March 1988.
Applicable Law and Constitutional Basis
Substantive law: Revised Penal Code provisions on Murder and qualifying circumstance of treachery; evidentiary rules concerning identification, corroboration, alibi, and witness credibility. Relevant Supreme Court precedents cited in the decision were applied. Constitutional framework: the 1987 Philippine Constitution (the Supreme Court decision was rendered in 1990 and therefore applies the 1987 Constitution).
Procedural History
The RTC, acting as a Special Criminal Court, convicted Norberto Clores of Murder with the qualifying circumstance of treachery, imposed the penalty of reclusion perpetua, ordered indemnity of P30,000 to the heirs of the victim, and assessed costs. Clores appealed to the Supreme Court raising three principal assignments of error challenging (1) reliance on the lone eyewitness, (2) the finding of treachery, and (3) the sufficiency of proof to establish guilt beyond a reasonable doubt. The Supreme Court affirmed the RTC decision.
Facts
On 24 December 1986 at about 2:00 a.m., eyewitness Celso Escobar, from a distance of approximately four arm‑lengths, saw Clores and “Jedy” suddenly attack and stab Rodolfo Reyes while the victim stood beside the road preparing to go home. Escobar testified the assailants stabbed the victim in turn—Clores with a bladed weapon about six to eight inches long and Jedy with a longer weapon about twelve to fourteen inches—until the victim fell. The weapons were not recovered. The victim made a scream but could not call for help and was later declared dead on arrival at the hospital. Escobar informed the victim’s relatives and accompanied the widow to report to police; Escobar assisted police in locating Clores, who was found asleep at his residence and was identified by Escobar as one of the assailants. Clores denied participation, asserted an alibi (he was at home after coming from work), and alleged Escobar had previously accosted him seeking money; Clores suggested Escobar’s identification was motivated by the earlier incident.
Issues Presented
- Whether the RTC erred in giving weight and credence to the testimony of the lone eyewitness, Celso Escobar.
- Whether treachery was properly found as a qualifying circumstance.
- Whether the evidence established Clores’s guilt beyond a reasonable doubt.
Ruling / Holding
The Supreme Court affirmed the RTC: Clores was guilty of Murder with treachery; penalty imposed was reclusion perpetua; he was ordered to indemnify the heirs P30,000 and to pay costs. The Court found no reversible error in the RTC’s credibility determinations and evidentiary conclusions.
Reasoning — Credibility and Sufficiency of the Lone Eyewitness
The Court reiterated that the testimony of a single credible and positive witness can sustain a conviction even for Murder; there is no general rule requiring corroboration except in specific offenses (e.g., treason). The RTC’s determination that Escobar’s testimony was “logical, straightforward and more probable” and that it was not shaken on cross‑examination was accorded respect because the trial court is in the best position to evaluate witness demeanor. The Court emphasized several factors supporting Escobar’s credibility: (a) Escobar’s sworn police statement was contemporaneous (same day) with the incident; (b) his testimony was consistent with physical evidence (he described a stab above the buttocks that corresponded to a medical certificate locating a wound on the trunk); (c) Escobar knew both Clores and the other assailant for a period before the incident and correctly described the proximity and setting; and (d) Escobar made an immediate identification before police at Clores’s residence, which demonstrated spontaneity and veracity. Given these factors, the Court held positive identification by a credible witness outweighed the defendant’s denials.
Reasoning — Alibi and Defendant’s Contradictions
The Court applied the well‑established rule that alibi is generally a weak defense and must be proved by positive, clear, and satisfactory evidence. It is insufficient merely to show the accused was elsewhere; the defense must demonstrate physical impossibility of presence at the scene to prevail. The RTC found Clores’s alibi implausible because the distance between his residence and the crime scene was roughly one‑half kilometer, making it feasible for him to be present. The Court also relied on material inconsistencies in Clores’s testimony (conflicting statements concerning the time he encountered Escobar and his work schedule) and his failure to present corroborative proof of his alibi. The Court concluded Clores’s denials and alibi were less credible than the positive identification by Escobar.
Reasoning — Treachery
The Court found the requisites of treachery satisfied. Escobar’s observation that Clores stabbed the victim above the buttocks established an attac
...continue readingCase Syllabus (G.R. No. 82362)
Court, Citation, and Panel
- 263 Phil. 585, Second Division, G.R. No. 82362, April 26, 1990.
- Decision authored by Justice Melencio-Herrera, J.
- Judgment of the Regional Trial Court (RTC) of Caloocan City, Branch 131, acting as a Special Criminal Court, dated 7 March 1988, was affirmed.
- Justices Paras, Padilla, Sarmiento, and Regalado concurred.
- The ponente noted a separate position in a referenced case (People vs. Munoz and Millora) as to the imposable penalty.
Nature of the Case and Relief Sought
- Criminal prosecution for Murder.
- Appellant: Norberto Clores y Coral (defendant-appellant).
- Plaintiff-Appellee: People of the Philippines (prosecution).
- Relief sought by appellant: reversal of conviction entered by the RTC and acquittal or new trial.
Trial Court Judgment and Sentence
- Appellant was found guilty of Murder.
- Qualifying circumstance found: treachery.
- Penalty imposed by the RTC: reclusion perpetua.
- Additional orders: indemnify the heirs of the victim in the amount of P30,000.00 and to pay the costs.
Material Facts as Found by the Prosecution (as narrated in the appealed Decision)
- Date and approximate time: 24 December 1986, at about 2:00 o’clock in the morning.
- Location: Zapote Street, Barangay 178, Camarin, Caloocan City.
- Victim: Rodolfo Reyes y de Paz.
- Lone eyewitness for the prosecution: Celso Escobar.
- Escobar's observation: from a distance of about four (4) arms lengths, he saw Appellant and a certain "Jedy" suddenly attack from behind and stab the victim, who was standing beside the road preparing to go home.
- Provocation: the victim had given no provocation whatsoever.
- Conduct of assailants: Appellant and Jedy took turns stabbing the victim until the victim fell to the ground; Clores used a bladed weapon about six (6) to eight (8) inches long, while Jedy used a longer weapon about twelve (12) to fourteen (14) inches in length.
- Weapons: neither weapon was recovered by the police from the crime scene.
- Victim’s reaction: unable to shout or ask for help although he gave out a scream before he expired.
- Discovery: incident attracted attention only after assailants had run away and victim had fallen flat on his face; other people loitering after the party then noticed.
- Medical response: victim rushed to Quezon City General Hospital and declared dead on arrival.
- Escobar’s immediate actions: did not go to the hospital but informed the victim’s brother-in-law who lived in front of the dance hall; shortly thereafter accompanied the victim’s widow to a police sub-station to report the incident.
- Police response and identification: two policemen proceeded to the crime scene and were thereafter assisted by Escobar in locating Appellant’s house; Appellant was found sleeping and was identified by Escobar as one of the assailants; Appellant was taken to Caloocan City Police Station and denied participation.
- Statements: Escobar and the victim’s widow, Mylvin Anson Reyes, gave sworn statements to the police.
Appellant’s Account and Defense
- Appellant’s narrated chronology: on 23 December 1986 at around 7:00 P.M., after coming from work, he was allegedly accosted by a man who introduced himself as Celso Escobar who asked for money to buy two cases of beer; Appellant claimed he gave Escobar the P35.00 in his pocket because Escobar appeared drunk and Appellant feared trouble.
- Later events: Appellant claimed to have observed a fistfight involving Escobar and an unidentified man while walking home, then went home, prepared supper and went to bed.
- Arrest and interrogation: around 4:00 o’clock in the morning of 24 December 1986, Appellant was awakened by police officers and taken to the Caloocan City Police Station; he was asked to identify the assailant but claimed he was not at the crime scene; was informed he was implicated by Escobar, which he denied.
- Alibi and alleged motive for implication: Appellant suggested his implication was because he had failed to give Escobar the amount Escobar was demanding.
Evidence Relating to Identification and Early Identification
- Escobar’s proximity: about four (4) arms lengths from the occurrence.
- Prior knowledge: Escobar had known Appellant for about a month and knew where Appellant resided, described as near the house of the victim.
- Identification at scene and to police: Appellant was identified by Escobar immediately after the incident to investigating police officers and during trial.
- Trial court’s description of Escobar: testimony characterized as "logical, straightforward and more probable" and not shaken by cross-examination.
- Importance of early identification: court treated early identification as indicative of spontaneity and veracity.
Credibility Findings by the Trial Court and Appellate Treatment
- Trial Court gave greater weight to the prosecution’s lone eyewitness, Celso Escobar, over Appellant’s alibi and denials.
- Appellate sta