GR L 22794; (January, 1968) (Digest)
March 12, 2026AC 3405; (March, 2014) (Digest)
March 12, 2026G.R. No. 94133 May 8, 1992
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLOS VILLANUEVA, accused-appellant.
FACTS
On April 11, 1988, in Surigao City, Police Sergeant Arturo Pelos was shot and killed. The information charged Carlos Villanueva with murder, committed with treachery and evident premeditation. Upon arraignment, Villanueva pleaded not guilty. The trial court found that on said date, the victim, Arturo Pelos, boarded a passenger motor launch bound for Surigao City, arriving at around 12:30 noon. After arrival, the victim and his nephew proceeded to an apartment on Kaimo Street. Prosecution witness Maribelle Galindo, walking behind the victim, was pushed aside by a man who then shot the victim twice—first in the back and then in the abdomen as he lay prostrate. The gunman fled. Galindo, along with another witness, Mary Grace dela Rama, who saw the shooting from her apartment door, positively identified the gunman as the accused, Carlos Villanueva. Their testimonies were corroborated by Alan Cabales. The victim was declared dead on arrival at the hospital. The accused interposed the defense of alibi, claiming he was on his way to Barangay Timamana at the time of the incident. The Regional Trial Court found Villanueva guilty of murder and sentenced him to reclusion perpetua.
ISSUE
Whether the trial court erred in convicting the accused despite the alleged failure of the prosecution to prove his guilt beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The defense of alibi failed as it did not satisfy the requirement of proving physical impossibility for the accused to be at the crime scene. The accused admitted being in Surigao City at the time of the shooting, and the distance between the jeepney terminal and the crime scene was only about half a kilometer, easily negotiable in minutes. The positive identification by prosecution witnesses, who had no improper motive to testify falsely, prevailed over the weak alibi. The relationship of some witnesses to the victim did not impair their credibility. Motive was unnecessary due to the positive identification. The penalty of reclusion perpetua was affirmed, but the civil indemnity was increased to Fifty Thousand Pesos (P50,000.00).