G.R. No. L-33357 July 29, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GUILLERMO EGARAS, CLETO EGARAS, and VICENTE EGARAS, defendants-appellants.

FACTS

The brothers Guillermo, Cleto, and Vicente Egaras were charged with murder for the killing of Eustaquio Hemor on March 26, 1970, in Barrio Salcedo, Dumarao, Capiz. The prosecution evidence, primarily from eyewitness Rafael Perote, established that at dusk, as Hemor and Perote walked home via railroad tracks, Hemor was suddenly shot by Guillermo. Guillermo then shouted to his brothers to bolo the victim. Cleto hacked the fallen Hemor multiple times with a bolo, and Vicente stabbed him several times with a pointed weapon. Perote, concealed by darkness, witnessed the entire attack and later reported the Egaras brothers to the police. The post-mortem examination revealed twenty-one wounds, eleven of which were fatal.
The defense of all three accused was alibi. Guillermo and Cleto claimed they were together in a store in Barrio Cubi, playing cards and drinking, at the time of the crime. Vicente alleged he was vacationing in Pototan, Iloilo. The trial court convicted all three of murder and sentenced each to reclusion perpetua. They appealed, challenging the credibility of the lone eyewitness and the finding of treachery.

ISSUE

The core issue is whether the trial court erred in convicting the appellants of murder based on the lone testimony of an eyewitness, rejecting their alibis, and finding the qualifying circumstance of treachery to be present.

RULING

The Supreme Court affirmed the conviction. The legal logic rests on the well-established principle that the assessment of witness credibility by the trial court is accorded high respect, as it is in a superior position to observe demeanor. The testimony of prosecution witness Perote was found to be credible, straightforward, and rich in detail that could not have been fabricated. The Court emphasized that witnesses are weighed, not numbered; the testimony of a single, credible eyewitness is sufficient to sustain a conviction.
The defense of alibi was correctly rejected. For alibi to prosper, the accused must demonstrate not only their presence elsewhere but also the physical impossibility of being at the crime scene. The appellants failed to do so. Barrio Cubi was merely two kilometers from the crime scene, a short train ride away. Vicente’s claim of being in Iloilo was uncorroborated. Furthermore, the alibis of Guillermo and Cleto actually placed them in the vicinity near the time of the crime. Their alibi could not prevail over Perote’s positive identification.
The qualifying circumstance of treachery (alevosia) was sufficiently proven. The attack was sudden and unexpected, executed in the dark against an unarmed victim who was walking home, giving him no opportunity to defend himself. This method ensured the execution of the crime without risk to the assailants. The Court modified the award by increasing the civil indemnity to P30,000.00 but otherwise affirmed the judgment in toto.