GR 135693; (April, 2002) (Digest)
G.R. No. 135693 . April 1, 2002.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CORNELIO GELIN and MANUEL GELIN, accused-appellants.
FACTS
The accused-appellants, brothers Cornelio and Manuel Gelin, were convicted of Murder for the killing of Dionisio Gelin. The prosecution evidence established that on February 10, 1991, the appellants, who were CAFGU members, accosted the victim’s son, Joel Gelin, due to a land dispute. They forced Joel at gunpoint and knifepoint to lead them to the victim’s house. Upon arrival, Cornelio immediately shot Dionisio, and Manuel then stabbed him in the chest. Prosecution eyewitness Ida Balagbis, who was in the house, corroborated Joel’s account, identifying the appellants at the scene. The post-mortem examination confirmed the victim sustained fatal gunshot and stab wounds.
The defense interposed alibi, claiming they were inside their CAFGU camp at the time of the incident. They presented fellow CAFGU members to support their claim. The trial court rejected this defense, finding the testimonies of the prosecution witnesses credible. It convicted the appellants of Murder qualified by treachery and sentenced them to reclusion perpetua. The appellants appealed, challenging the credibility of the prosecution witnesses and the rejection of their alibi.
ISSUE
Whether the trial court erred in convicting the accused-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 upheld the trial court’s assessment of witness credibility, noting that minor inconsistencies in the testimonies of Joel Gelin and Ida Balagbis did not detract from their core narrative, which was consistent and credible. Both witnesses positively identified the appellants as the perpetrators. The defense of alibi was correctly dismissed as it was not physically impossible for the appellants to have been at the crime scene. Their camp was merely 1.5 kilometers away, and their alibi was supported solely by the testimonies of friends and comrades, which are inherently suspect. The qualifying circumstance of treachery was properly appreciated, as the attack was sudden and unexpected, denying the victim any chance to defend himself. The Court modified the damages awarded, ordering the appellants to jointly and severally pay the heirs of the victim P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P459,000.00 for loss of earning capacity.