G.R. Nos. L-72028-31. November 9, 1987.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CENON BRIOSO, SEVERINO BRIOSO, and MONICO VITAMOG, accused-appellants.

FACTS

Accused-appellants Cenon Brioso, Severino Brioso, and Monico Vitamog were charged with Murder for the deaths of spouses Cresencio and Erlinda Vitamog, and with Frustrated Murder for the serious injuries inflicted upon their children, Kennedy and Presley Vitamog. The attack occurred at midnight on March 15, 1983, in San Juan, Ilocos Sur, while the family was asleep in a makeshift shed. The prosecution’s narrative, primarily through the testimony of the surviving child Kennedy, was that three intruders entered the shed and clubbed the victims with bamboo stumps. Kennedy identified the three accused as the assailants before he himself was chased and clubbed by Cenon Brioso, rendering him unconscious.
The police found the spouses dead and the children seriously wounded at the scene, along with blood-stained bamboo stumps. Autopsies confirmed the victims died from fatal head wounds caused by a blunt instrument like bamboo. Strands of hair were found clutched in Erlinda Vitamog’s hand, which the National Bureau of Investigation later examined. The defense consisted of alibis, which the trial court rejected.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellants beyond reasonable doubt, particularly concerning the credibility of the eyewitness identification and the corroborative value of the hair strand evidence.

RULING

The Supreme Court affirmed the convictions. The Court upheld the trial court’s assessment of Kennedy Vitamog’s credibility as an eyewitness. His positive identification of the three accused was deemed credible and reliable, notwithstanding his youth, as he had a clear view of the assailants by the light of a kerosene lamp and during the chase. The Court emphasized that the trial court’s findings on witness credibility are entitled to great weight and respect.
Regarding the hair evidence, the Court clarified that while the NBI expert stated the hair strands from Erlinda’s grip were “similar” to samples from Severino Brioso and “could have originated” from him, this finding alone was not the sole basis for conviction. The Court ruled this forensic evidence was merely corroborative of the direct, positive identification made by Kennedy. The combination of the eyewitness testimony and the corroborative physical evidence sufficiently established the appellants’ guilt. The defense of alibi was correctly dismissed for being weak and unsubstantiated. Thus, the penalties of Reclusion Perpetua for the Murder convictions and the imposed prison terms for the Frustrated Murder convictions were affirmed.