G.R. No. 215320 February 28, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. MANUEL CORPUZ, Accused-Appellant

FACTS

Accused-appellant Manuel Corpuz was charged with two counts of Murder for the deaths of Romana Arcular and Leonila Risto on October 29, 2004, in Abuyog, Leyte. The prosecution’s case primarily hinged on the eyewitness account of Leonilo Bongalan, Leonila’s son-in-law. He testified that around 4:00 p.m., he went to check on Leonila at her farm and saw Corpuz hacking both victims with a bolo. Leonilo immediately reported the incident to the barangay captain and the police. Corroborative testimony was provided by two other witnesses, Pedro Dejaresco and Teodoro Queri-queri, who stated they saw Corpuz, half-naked and holding a bolo, coming from the direction of the crime scene around the same time. The medical findings confirmed both elderly victims sustained fatal hack wounds.
The defense interposed alibi and denial. Corpuz claimed he was plowing a rice field in a neighboring barangay from 8:00 a.m. until 4:30 p.m. on the day of the incident, and only learned of the killings upon his arrest. His wife, Annabelle, corroborated his alibi, testifying she was cooking at the same location and they returned home together around 6:00 p.m. The defense also highlighted an entry in the police blotter, made from Leonilo’s initial report, which stated the suspect was “unknown” and that Leonilo saw the dead bodies, without an explicit mention of witnessing the actual hacking.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused beyond reasonable doubt, specifically in overcoming the defenses of alibi and denial with positive identification, and in establishing the qualifying circumstance of treachery.

RULING

The Supreme Court affirmed the conviction for two counts of Murder. The Court upheld the credibility of eyewitness Leonilo Bongalan. His positive identification of Corpuz, whom he knew prior to the incident, was given full weight. The fact that the crime occurred in broad daylight bolstered the reliability of his account. The Court ruled that the minor inconsistency between his courtroom testimony and the police blotter entry did not destroy his credibility. A police blotter is merely a preliminary record of events, not a complete or sworn statement, and it is natural for a witness to provide more detailed testimony during trial. The testimonies of the corroborating witnesses who placed Corpuz near the scene further strengthened the prosecution’s case.
The defenses of alibi and denial were correctly rejected. For alibi to prevail, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of being at the crime scene. Corpuz failed this test, as the defense’s own evidence showed the location where he claimed to be was merely 200 meters away from the crime scene, making it easily accessible. Denial, being inherently weak, cannot prevail over the positive and credible testimony of an eyewitness. The qualifying circumstance of treachery was sufficiently established. The attack was sudden and unexpected, employing a bolo against two elderly, unarmed women, deliberately ensuring they had no opportunity to defend themselves. This method of execution directly and specifically aimed to accomplish the killing without risk to the assailant.