G.R. Nos. 101122-23 December 9, 1992
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LUCIANO ALBORES y TARAN, alias Dodong, accused-appellant.

FACTS

Accused-appellant Luciano Albores y Taran was charged with Murder for the killing of Eugenia Gumapac and Frustrated Murder for the stabbing of Ellen Gumapac, alleged to have occurred at dawn on May 10, 1987, in Kibawe, Bukidnon. The prosecution’s lone eyewitness was Ellen Gumapac, who testified that while she and her mother were sleeping, their house was stoned. After they closed the windows and doors, the accused went upstairs, stabbed her mother, dragged her away, then chased, caught, stabbed, and dragged Ellen to a river. The defense interposed alibi, with accused and witnesses Martino Antipuesto and Gonzalo Padrigo testifying he was at Kanapolo, Davao del Sur, about 200 kilometers away, attending mass from 7:00-9:00 a.m. on May 10, 1987. The prosecution presented a rebuttal witness, Myrna Casinabe, who testified that as election board chairman, she saw the accused cast his vote in Romago-oc, Bukidnon, on May 11, 1987, contradicting the alibi for that date. The trial court convicted the accused, giving credence to Ellen’s testimony and rejecting the alibi as a fabrication, and sentenced him to Reclusion Perpetua for Murder and an indeterminate penalty for Frustrated Murder.

ISSUE

Whether the trial court erred in convicting the accused based on the prosecution’s evidence and in totally disregarding the defense of alibi.

RULING

The Supreme Court REVERSED the trial court’s joint decision and ACQUITTED the accused-appellant based on reasonable doubt. The Court held that while alibi is a weak defense, the constitutional presumption of innocence is paramount. The trial court rejected the alibi mainly due to Myrna Casinabe’s testimony, which only contradicted the accused’s whereabouts on May 11, 1987, not on May 10, 1987, the date of the crime. Two defense witnesses testified they saw the accused at church around 7:00 a.m. on May 10, about 200 kilometers from the crime scene. Furthermore, the Court found doubts in the prosecution’s case: Ellen Gumapac initially told Sergio Mendez she did not recognize her assailant, only describing his clothing, and failed to immediately identify the accused despite having the opportunity after the attack. This unexplained initial silence, coupled with the improbability of the accused being at the crime scene less than three hours before attending mass 200 kilometers away, created reasonable doubt as to his guilt.