G.R. No. L-48269 August 15, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RIZAL IDNAY y BATARA, accused-appellant.

FACTS

The prosecution evidence established that on November 12, 1976, accused-appellant Rizal Idnay was at a restaurant in Badoc, Ilocos Norte. After drinking beer without paying and forcing others to settle his bills, the restaurant owner, Nicolas Bautista, forcibly ejected him. Outside, Idnay threatened, “You wait, I will come back and kill one among you.” About ten minutes later, Bautista heard a child crying and instructed his son, Benedicto, to check on his five-year-old brother, Ronald, who had earlier taken bottles outside. Benedicto saw Idnay about eight meters away, holding Ronald with his left hand and making a downward swinging motion with his right “as if whipping.” Idnay fled upon being shouted at. Ronald was found prostrate with stab wounds and was pronounced dead on arrival at the hospital. The post-mortem examination revealed five clean-cut wounds from a sharp instrument, with severe hemorrhage as the cause of death.
The defense interposed an alibi. Idnay claimed he was drinking with companions at the restaurant but left with them shortly after the altercation with the owner. They allegedly proceeded to Barrio Balbaldez, about eight kilometers away, to continue drinking and slept there. He was arrested the next day. His testimony was corroborated by a companion, Edgar Pagdilao, who stated they left Idnay at the restaurant briefly and that Idnay was with them in Balbaldez that evening. The trial court disbelieved the defense, convicted Idnay of Murder, and sentenced him to reclusion perpetua.

ISSUE

Whether the trial court erred in convicting the accused based on the credibility of the prosecution witnesses and in rejecting the defense of alibi.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s findings on credibility, which are generally accorded great weight. Prosecution witness Benedicto Bautista positively identified Idnay from a distance of eight meters in the act of assaulting the victim. Benedicto had seen Idnay in the restaurant at least five times prior, ensuring reliable identification. The sequence of events—the threat, the short interval, and the immediate discovery of the crime—strongly pointed to Idnay’s guilt.
The defense of alibi was correctly rejected. For alibi to prosper, the accused must demonstrate it was physically impossible to be at the crime scene. Idnay failed to meet this strict requirement. The defense’s own evidence showed Barrio Balbaldez was only about eight kilometers from the crime scene in Badoc. Given the availability of motorized transportation, it was not impossible for Idnay to have committed the crime and later reached Balbaldez. Alibi cannot prevail over positive identification, which was established by clear prosecution testimony.
Regarding the penalty, the Court noted that with the abolition of capital punishment under the 1987 Constitution , the penalty for Murder is reclusion temporal maximum to reclusion perpetua. With no modifying circumstances, the medium period applies. Applying the Indeterminate Sentence Law, the Court modified the sentence to an indeterminate penalty of ten years and one day of prision mayor, as minimum, to eighteen years, eight months, and one day of reclusion temporal, as maximum. Civil indemnity was increased to P30,000.00.