G.R. No. L-29340 April 27, 1972
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DEMETRIO SALES, accused-appellant.

FACTS

Demetrio Sales was accused of murdering his neighbor, Ciriaco Betonio, who was found dead in his house on November 19, 1964. The prosecution presented two eyewitnesses, houseboy Alberto Limocon and housemaid Sinforosa Pacatang. They testified that on the afternoon of November 18, Sales arrived at Betonio’s house carrying a club, asked for the victim, and upon learning he was asleep, entered the room and struck him. Fearing for their lives after Sales threatened them, the witnesses fled and later, by chance, sought shelter in what turned out to be Sales’s own house. They remained there for days, only revealing the incident to the victim’s family after they had left, attributing their silence to fear of the accused’s threats. The defense presented witnesses, including Sales’s wife, to establish an alibi, claiming Sales was elsewhere during the incident. The trial court convicted Sales of murder and sentenced him to life imprisonment.

ISSUE

The core issue is whether the guilt of the accused was proven beyond reasonable doubt, considering the credibility of the eyewitness accounts and the defense of alibi.

RULING

The Supreme Court affirmed the conviction. The Court found the testimonies of the prosecution eyewitnesses credible and sufficient to establish guilt. The witnesses provided a clear, consistent, and spontaneous account of the crime. Their initial failure to immediately report the incident was satisfactorily explained by the reasonable fear instilled by the accused’s direct threats to kill them if they told anyone. The Court held that delay in reporting a crime, when justified by fear of reprisal, does not impair a witness’s credibility. Furthermore, the act of seeking shelter in the accused’s house was not an indication of trust but a result of their terrified state and lack of alternatives, which did not negate their account of the assault.
The defense of alibi was rejected as inherently weak. For alibi to prevail, it must be shown that the accused was so far away that it was physically impossible for him to have been at the scene of the crime. The defense failed to meet this rigorous standard. The positive identification by credible eyewitnesses, who had no motive to falsely testify, prevails over an unsubstantiated alibi. The Court also noted that the nature and location of the victim’s head injuries, as described by the medico-legal expert, were consistent with a forceful blow from a blunt instrument like a club while the victim was lying down, corroborating the eyewitness narrative. The penalty of life imprisonment was affirmed as proper for murder with no modifying circumstances, but the civil indemnity was increased to P12,000.00 in line with prevailing jurisprudence.