G.R. No. 122101 . April 30, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GODOFREDO MARFIL, accused-appellant.

FACTS

On the evening of April 29, 1988, accused-appellant Godofredo Marfil, along with his sons Lopito and Gomer, approached the house of Cirilo Melancio in Barangay Binay, Magpet, Cotabato. They called for Cirilo, with Godofredo stating he was thirsty and asking for the door to be opened. The family, peeping through the window, saw the three men armed with high-powered rifles. Fearing for their lives, they did not open the door and turned off the lights. Cirilo then saw the accused move back from the house, anticipating an attack, and ordered his family to take cover.
The accused proceeded to strafe the house. The attack resulted in the instantaneous deaths of four of Cirilo’s children: Merlinda, Marivel, Jurry, and Jenaline. Three other children, Joel, Marivic, and Jennifer, sustained serious gunshot wounds but survived after medical intervention. The accused then killed the family’s pig, with Godofredo remarking it was for their funeral. The accused-appellant raised the defense of alibi, claiming he was at home sick and being massaged by the barangay chairman at the time of the shooting.

ISSUE

Whether the trial court erred in convicting accused-appellant Godofredo Marfil of multiple murder and multiple frustrated murder based on the prosecution’s evidence and in rejecting his defense of alibi.

RULING

The Supreme Court affirmed the conviction. The positive identification of the accused-appellant by the victims, Cirilo Melancio and his surviving children Joel and Marivic, was deemed credible and sufficient to establish guilt beyond reasonable doubt. The Court emphasized that alibi is inherently a weak defense and cannot prevail over clear and positive identification. The trial court’s assessment of witness credibility was accorded great respect, as no arbitrariness or oversight of material facts was demonstrated.
The Court found the alibi untenable, noting that accused-appellant’s claimed location was merely one kilometer from the crime scene and was thus not physically impossible for him to have been present at the locus criminis. The failure of the local police to act promptly, partly because one co-accused was a soldier, explained the family’s recourse to the Commission on Human Rights and did not undermine the prosecution’s case. The attack, directed at a dwelling known to house a family with young children, was characterized by treachery, qualifying the killings as murder. The penalties imposed by the trial court were therefore upheld.