GR L 45214; (January, 1987) (Digest)
G.R. No. L-45214. January 29, 1987.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DIONISIO DELA CRUZ and JULIO DELA CRUZ, defendants-appellants.
FACTS
The appellants, father and son Dionisio and Julio dela Cruz, were convicted of double murder for the killing of spouses Meliton and Emilia Abobon on the night of April 17, 1975, in Labrador, Pangasinan. The victims were found with multiple fatal hack and stab wounds near their hut by a saltbed. The prosecution’s case rested primarily on the testimonies of two eyewitnesses, neighbors Abraham Malong and Rebecca Acosta. Malong testified he heard screams, approached stealthily, and from 25-30 meters away, saw under bright moonlight and the light from a lamp and cooking flames, the appellants and an unidentified companion hack the victims. Acosta testified she was awakened by screams, looked out her window from about 70 meters away, and saw three men, whom she identified as the appellants, fleeing the scene under the same illuminating conditions. The defense was alibi, claiming they were elsewhere.
ISSUE
The core issue was whether the testimonies of the prosecution eyewitnesses were credible and sufficient to establish the guilt of the appellants beyond reasonable doubt, overcoming their defense of alibi.
RULING
The Supreme Court affirmed the conviction. The Court meticulously upheld the trial court’s assessment of witness credibility, finding no reason to deviate from it. The legal logic proceeded as follows: First, the conditions of visibility were adequately established. The witnesses consistently described the illumination from a bright moon, a hanging lamp, and the flames from salt-cooking ovens, which provided sufficient light for positive identification at the distances involved. The Court noted that moonlight, coupled with artificial light, can indeed permit recognition, especially among individuals known to each other in a rural community. Second, the witnesses had no improper motive to falsely testify against the appellants. Their natural hesitation and initial fear in coming forward, as explained by Malong, were deemed understandable reactions to witnessing a brutal crime and did not impair their credibility. Third, the alleged inconsistencies in their testimonies were minor and pertained to collateral details, which did not affect the veracity of their core account of the crime and their identification of the assailants. The Court emphasized that testimonies need only corroborate on material points. Fourth, the defense of alibi was inherently weak and could not prevail over the positive identification by credible witnesses. The appellants failed to prove it was physically impossible for them to be at the crime scene. The Court also found the motive of revenge, rooted in the appellants’ belief that the victims were witches responsible for family misfortunes, to be plausible in the context of the locality. Consequently, all elements of murder qualified by treachery were proven beyond reasonable doubt.
