G.R. No. L-32914 August 30, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LAUREANO SANGALANG, accused-appellant.

FACTS

On June 9, 1968, Ricardo Cortez was gathering tuba from a coconut tree in Silang, Cavite. His wife, Flora Sarno, heard gunshots and witnessed from about twenty-five meters away five armed men, including Laureano Sangalang, firing at her husband. She recognized Sangalang, a person known to her since childhood. Cortez fell from the tree and was shot multiple times while on the ground. Flora attempted to approach but was fired upon, forcing her to retreat. Her brother, Ricardo Sarno, who was nearby, also witnessed the attack and identified Sangalang as one of the assailants armed with a Garand carbine. The victim sustained twenty-three gunshot wounds and died. The following day, Flora and Ricardo executed sworn statements identifying Sangalang and four others as the perpetrators.
The accused, Laureano Sangalang, pleaded an alibi. He claimed he was in Manila on the day of the crime to borrow money, supported by corroborating witnesses. He argued that the prosecution witnesses’ testimonies were inconsistent and insufficient to overcome his defense.

ISSUE

The core issue is whether the positive identification of the accused by two eyewitnesses is sufficient to convict him of murder, thereby overcoming his defense of alibi.

RULING

The Supreme Court affirmed the conviction. The legal logic centers on the established jurisprudential principle that positive identification by credible witnesses prevails over an alibi, which is inherently weak and easily fabricated. The Court found the testimonies of Flora Sarno and Ricardo Sarno credible and consistent on the material point of identifying Sangalang as a participant in the killing. Minor discrepancies in their accounts were deemed natural and even bolstered their credibility, indicating unrehearsed testimony. In contrast, Sangalang’s alibi was rejected, particularly noting his failure to raise this defense during initial police investigation and preliminary examination, undermining its plausibility.
The Court ruled that the manner of attack constituted treachery (alevosia). The victim, unarmed and defenseless while atop a coconut tree, was suddenly assaulted by a volley of gunshots, ensuring the execution without risk to the assailants. This qualifying circumstance elevated the crime to murder. Evident premeditation was not proven. The penalty of reclusion perpetua imposed by the trial court was affirmed, along with the award of indemnity and moral damages. The decision underscores that alibi cannot stand against positive identification absent evidence of improper motive on the part of the witnesses.