G.R. No. 79039 -41 October 27, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAMERTO ALTERADO, JR. and GILBERTO PATAGNAN, accused-appellants.

FACTS

On the evening of July 6, 1985, Victor Gaquit and Maribeth Maglasang were sitting on a bench outside Maribeth’s house in Ormoc City when they were fired upon by two individuals. Maribeth was killed, sustaining seven gunshot wounds, and Gaquit was injured. Eyewitness Victor Gaquit positively identified appellant Mamerto “Bimbo” Alterado, Jr. as one of the assailants, recognizing him after the shooting ceased. Another eyewitness, Angelina Maurillo, who was nearby, also identified Alterado and his companion, who was carrying a long firearm, as the perpetrators. Shortly after the incident, Federico Castillo saw two men jogging away and heard one, whom he identified as Alterado, say, “I am sure that one is dead.” Police, acting on tips, later found the appellants at Alterado’s apartment, where an M-16 rifle magazine was recovered.
The appellants denied involvement and presented an alibi, claiming they were at the Don Felipe Hotel at the time of the shooting. They also highlighted the negative paraffin test results from samples taken four days post-incident and pointed to alleged inconsistencies in the prosecution witnesses’ testimonies.

ISSUE

The core issue is whether the prosecution evidence, particularly the eyewitness identifications, is sufficient to overcome the appellants’ defenses of alibi and to prove their guilt for Murder and Slight Physical Injuries beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the eyewitness testimonies of Gaquit and Maurillo as credible and convincing. It ruled that the alleged inconsistencies were minor and pertained to trivial details, which actually bolstered the witnesses’ credibility by showing a lack of rehearsal. The positive identifications rendered the defense of alibi, which is inherently weak, unavailing. The Court noted the scene of the crime and the hotel were merely 0.8 kilometers apart, making it physically possible for the appellants to have committed the crime and later been at the hotel. Regarding the negative paraffin test, the Court cited expert testimony that gunpowder residue completely disappears after four days, making the test results inconclusive and unreliable. The absence of a clear motive was also deemed inconsequential, as the positive identification of the perpetrators was sufficient to establish guilt. Thus, the evidence collectively established the appellants’ guilt beyond reasonable doubt.