G.R. No. 76048 May 29, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BONIFACIO PIGON, accused-appellant.

FACTS

Accused-appellant Bonifacio Pigon was convicted by the Regional Trial Court of robbery with homicide for the killing of Leonito Samson and sentenced to reclusion perpetua. The prosecution’s case rested primarily on the eyewitness account of Jaime Deogrades, then 14 years old. Deogrades testified that on December 29, 1983, he, Pigon, and the victim were walking single file to Pigon’s house to conclude a barter of a goat for the victim’s shoes and cash. Upon reaching Barangay Galutan, Pigon suddenly grabbed Samson from behind and, as Samson turned, stabbed him in the chest with a “flamingo” knife. Pigon then robbed the victim of his clothing, wallet, and money, fled with Deogrades, and detained him for several days with a threat not to disclose the incident. Deogrades reported the crime only after Pigon’s arrest. Autopsy findings confirmed death from a stab wound consistent with the eyewitness account.
The defense presented an alibi. Pigon, corroborated by witness Pedro Yanson, claimed he was in San Rafael, assisting in preparations for a birthday party from the afternoon of December 28 until 3:00 p.m. on December 29, 1983, thus making it impossible for him to be at the crime scene in Galutan at 3:00 a.m. when the incident allegedly occurred. The defense asserted the physical distance between the locations precluded his presence.

ISSUE

The core issue is whether the trial court erred in convicting Pigon based on the testimony of Jaime Deogrades and in rejecting his defense of alibi, despite his claim that his guilt was not proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of Deogrades’ credibility, finding his testimony clear, straightforward, and consistent. As an eyewitness, his detailed account of the stabbing and subsequent robbery was deemed credible and sufficient to establish Pigon’s guilt. The Court emphasized that the testimony of a single credible witness is adequate for a conviction if it meets the standard of proof beyond reasonable doubt.
Regarding the alibi, the Court ruled it must fail against positive identification. For alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of being at the crime scene at the time of its commission. The defense failed on both counts. The Court noted that the distance between San Rafael and Galutan within the same municipality was not prohibitive, and the defense witness could not have continuously monitored Pigon’s movements amidst party preparations. Consequently, the alibi was inherently weak and could not overcome the positive identification by the prosecution witness. The decision of the trial court was therefore affirmed in its entirety.