GR 96230; (May, 1991) (Digest)
G.R. No. 96230 ; May 27, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIO CUSTODIO y ESPIRITU, accused-appellant.
FACTS
On the evening of August 10, 1986, during a wake at a chapel in Naga City, Danilo Camba was fatally stabbed. Prosecution eyewitness Corazon Nono, who was seated facing Camba, testified that she saw accused-appellant Mario Custodio approach from behind the victim and stab him twice with a bladed weapon. She positively identified Custodio, whom she knew well, and stated she heard the victim exclaim he was stabbed by Mario. Two other witnesses, Edwin Ejercito and Manuel Nono, corroborated the event, with Ejercito seeing Custodio make a downward thrust and flee, and Manuel Nono hearing the victim name Custodio as his assailant while being transported to the hospital.
The defense presented an alibi, with Custodio claiming he was asleep at his home approximately 200 meters away at the time of the incident. He also attempted to implicate a certain Perfecto del Rosario, but neither this individual nor any written confession from him was presented in court. The trial court convicted Custodio of murder, a decision affirmed by the Court of Appeals with a modification of the penalty to reclusion perpetua and an increase in civil indemnity.
ISSUE
Whether the Court of Appeals erred in affirming the conviction based on the credibility of the prosecution witnesses and in rejecting the defense of alibi.
RULING
The Supreme Court affirmed the conviction. The Court held that minor inconsistencies in the testimonies of eyewitnesses, particularly Corazon Nono, regarding peripheral details do not undermine their credibility but instead suggest truthfulness and lack of rehearsal. The core narrative of all prosecution witnesses remained consistent: they positively identified Custodio as the perpetrator who stabbed the victim and then fled. The Court further found that the defense of alibi is inherently weak and cannot prevail against the positive identification by credible witnesses. Custodio’s own admission placed him only 200 meters from the crime scene, failing to meet the requisite proof of physical impossibility of being present. The existence of prior animosity between Custodio and the victim’s family, as noted by the trial court, provided further context for the motive, though motive becomes secondary when positive identification is established. Consequently, the judgment of the Court of Appeals was upheld.