GR 101312; (January, 1997) (Digest)
G.R. No. 101312 January 28, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROBERT DINGLASAN y MANGINO @ OBET, REYNALDO TAPIA y SORAO, and MANOLO BONGALOS @ MANOLO, accused; ROBERT DINGLASAN y MANGINO @ OBET, accused-appellant.
FACTS
On September 5, 1990, in Pasig, Metro Manila, Efren Lasona was fatally stabbed. Eyewitness Rolando Quintanilla testified that he was with Lasona when accused-appellant Robert Dinglasan, along with Reynaldo Tapia, Manolo Bongalos, and a certain “Jetlee,” arrived. As Lasona alighted from a tricycle, Bongalos and “Jetlee” blocked his path. Tapia and Bongalos then repeatedly stabbed Lasona. Quintanilla stated that Dinglasan held or embraced the victim during the attack, while “Jetlee” aimed a “pana” (arrow) to prevent assistance.
Another eyewitness, Rosario Santos, corroborated the account, testifying that she saw Dinglasan hold the victim’s hands from behind, rendering him immobile while three other persons stabbed him. The autopsy confirmed Lasona died from multiple stab wounds. Dinglasan was charged with murder. At trial, he interposed the defense of alibi, claiming he was at a different location attending a birthday party at the time of the killing.
ISSUE
The core issue is whether the prosecution proved the guilt of accused-appellant Robert Dinglasan for the crime of murder beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court found the positive identification by two eyewitnesses, Quintanilla and Santos, to be credible and consistent. Their testimonies established that Dinglasan actively participated by restraining the victim, which facilitated the stabbing by his cohorts. This constituted conspiracy, making Dinglasan equally liable for the acts of his co-accused.
The Court rejected Dinglasan’s alibi as inherently weak. For alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of being at the crime scene. Dinglasan failed to prove this impossibility, as the location of the party was not so distant as to preclude his presence at the crime scene. Positive identification by credible witnesses prevails over a dubious alibi.
Furthermore, the Court upheld the qualifying circumstance of treachery (alevosia). The attack was sudden and unexpected, with the victim being restrained by Dinglasan, rendering him defenseless and unable to retaliate or escape. This manner of execution ensured the assailants’ safety from any defense the victim might offer. The penalty of reclusion perpetua and the awarded civil indemnities were thus affirmed.