G.R. No. L-32163 October 19, 1976
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO ALONZO, RENATO HERNADO, ROLANDO GAÑO and JUAN VILLOSILLO alias “Ilocano”, defendants-appellants.

FACTS

The prosecution’s evidence established that on the afternoon of April 29, 1966, in Balanga, Bataan, appellants Antonio Alonzo, Renato Hernando, Rolando Gaño, and Juan Villosillo inquired about the whereabouts of Wilfredo Flores. Later that evening, witness Sebastian Estember accompanied Flores on his way home. While passing in front of the Orchid Refreshment and Victory Lumber, the four appellants emerged, surrounded Flores, and Antonio Alonzo stabbed him twice, causing his immediate death. The autopsy confirmed death resulted from hemorrhagic shock due to the stab wounds.
The defense for all four appellants consisted solely of alibi. Each claimed to have been in a different location at the time of the crime: Villosillo harvesting peanuts in Niyugan; Gaño guarding a bulldozer in Nagwaling; Hernando and his father watering their farm in Maulang; and Alonzo staying in his farm in Lupang Tagalog. They presented corroborating witnesses for their respective whereabouts. The trial court convicted all four of murder, qualified by treachery, and sentenced them to reclusion perpetua.

ISSUE

The central issue is whether the trial court erred in convicting the appellants of murder based on the prosecution’s evidence and in rejecting their defense of alibi.

RULING

The Supreme Court affirmed the conviction. The Court held that the positive identification of the appellants by prosecution witness Sebastian Estember, who knew them and clearly narrated their concerted actions leading to the stabbing, prevailed over their weak defenses of alibi. For alibi to succeed, the defense must demonstrate not only that the accused was elsewhere when the crime occurred but that it was physically impossible for him to have been at the scene of the crime. The appellants failed to meet this stringent requirement. The places they cited were all within the same province of Bataan, and no evidence was presented to prove the absolute impossibility of their travel to and from Balanga within the relevant timeframe.
Furthermore, the Court found the qualifying circumstance of treachery (alevosia) to be properly appreciated. The attack was sudden and unexpected, executed in a manner that deprived the victim, Wilfredo Flores, of any opportunity to defend himself or retaliate. The appellants employed a strategy of lying in wait, ganging up on the victim, and ensuring the attack was swift and fatal. The collective actions of the four individuals constituted conspiracy, as evidenced by their coordinated conduct before and during the assault, making each of them equally liable for the crime of murder. The judgment of the trial court was affirmed in toto.