G.R. No. 101829 August 21, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BONIFACIO ZAMORA, et al., accused. BONIFACIO ZAMORA, accused-appellant.

FACTS

On the evening of September 20, 1984, Mandatu Luntayan, Sr. was fatally hacked by multiple assailants along a barangay road in Midsayap, Cotabato. His wife, Lucila, and son, Mandatu, Jr., who were waiting for him at their house nearby, heard a tricycle stop and went to investigate. Using a flashlight, they witnessed the victim being hacked by three men. From a distance of about ten meters, they positively identified the assailants as their long-time neighbors: Julio Alvarino, Felix Saladar, and accused-appellant Bonifacio Zamora. The victim was brought to a clinic but died from massive blood loss due to seven hack wounds. Appellant Zamora, along with others, was charged with Murder.
The defense interposed alibi. Zamora claimed he was at his brother’s house, merely ten meters from the crime scene, listening to the radio at the time of the incident. He asserted it was physically impossible for him to have been at the location of the killing. The trial court, however, found the prosecution’s eyewitness accounts credible and convicted Zamora of Murder, sentencing him to reclusion perpetua and ordering him to pay indemnity and damages.

ISSUE

Whether the trial court erred in convicting accused-appellant Bonifacio Zamora based on the eyewitness identification, despite his defense of alibi and alleged inconsistencies in the testimonies.

RULING

The Supreme Court affirmed the conviction. The Court reiterated the settled rule that positive and categorical declarations of credible eyewitnesses who identify the accused as the perpetrator of the crime are accorded greater evidentiary weight than the defenses of denial and alibi. The identification by the victim’s wife and son, who had known Zamora as a neighbor for over five years, was made under sufficient illumination from their flashlight and at a short distance, rendering it reliable. Minor inconsistencies in their testimonies regarding peripheral details, such as the exact time or the specific actions of each assailant, do not undermine their core narrative but instead suggest spontaneity and lack of rehearsal. For alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of his being at the locus criminis. Zamora’s alibi failed this test, as his brother’s house was merely ten meters away, making it not only possible but easy for him to have committed the crime and returned. The Court found no reason to disturb the trial court’s assessment of witness credibility. The qualifying circumstance of treachery was duly proven, as the attack was sudden and deliberate, rendering the victim defenseless. The penalty of reclusion perpetua and the awarded damages were sustained.