G.R. No. 92505 ; April 30, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALEJANDRO MOTAR, SALVADOR MAGPILI, ROMULO DEL MUNDO AND RICARDO GOLEZ, accused. ALEJANDRO MOTAR AND SALVADOR MAGPILI, accused-appellants.

FACTS

The prosecution’s case, based on eyewitness accounts, established that on December 13, 1987, the victim Pedro Artificio went to collect a debt from Romulo del Mundo at the house of Salvador Magpili. His common-law wife, Merlita Pradejas, followed him later with a companion, Norberto Mores. As they approached, they met Pedro running, warning them he was being chased by four armed men. From hiding, Merlita and Norberto witnessed Alejandro Motar hack Pedro on the neck, causing him to fall, after which Romulo del Mundo stabbed him and Ricardo Golez and Salvador Magpili took turns hacking him with bolos. The autopsy confirmed multiple fatal hack and stab wounds. Police found blood trails and two bolos hidden near the scene.
The defense, primarily through alibi, claimed Motar and Magpili were threshing palay in a distant ricefield until 9:00 PM and learned of the killing only upon returning home. They pointed to the fleeing co-accused, Del Mundo and Golez, as the sole perpetrators. A defense witness, Romeo Trinidad, corroborated the chase and killing but also implicated only Del Mundo and Golez.

ISSUE

Whether the trial court erred in convicting accused-appellants Motar and Magpili of Murder based on the identification by prosecution witnesses and in rejecting their defense of alibi.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the credibility of eyewitness identification and the weakness of alibi. The Court found the testimonies of prosecution eyewitnesses Merlita and Norberto clear, positive, and consistent, and their presence at the scene was natural. Their account was corroborated by physical evidence: the discovery of two bolos matched their testimony on the weapons used, and the blood trail confirmed the pursuit. The defense witness Trinidad, while trying to exculpate appellants, unwittingly confirmed the fact of a chase. The defense of alibi was inherently weak and unpersuasive. The ricefield was only about 1.5 kilometers away, making it feasible for appellants to have been at the crime scene. The claim of threshing until 9:00 PM on a moonless night was deemed improbable. The Court deferred to the trial court’s superior position to assess witness credibility. Appellants’ non-flight was not exculpatory, as they likely believed they could blame their absent co-accused. The qualifying circumstance of abuse of superior strength was correctly appreciated. The indemnity was increased to P50,000.00.