G.R. No. 104662 June 16, 1995
The People of the Philippines, plaintiff-appellee, vs. Leonardo Lopez y Mancilla, Jr., accused-appellant.

FACTS

Accused-appellant Leonardo Lopez y Mancilla, Jr. was charged with the murder of Jesus Reyes. The prosecution’s evidence established that on August 8, 1990, in Manila, the victim, along with Evelyn Paras and Edgardo Castro, went to a barangay hall to file a complaint against the appellant’s brother. The appellant suddenly appeared and, in a swift motion, stabbed Reyes in the back. As Reyes fled, the appellant pursued him, stabbed him a second time after he fell, and then fled the scene. Reyes died from his wounds. The appellant was arrested seven months later.
The appellant interposed the defense of alibi, claiming he was asleep in his house approximately thirteen meters away at the time of the incident and only learned of it afterwards. He challenged his conviction, arguing that the prosecution witnesses’ identification was unreliable and that his guilt was not proven beyond reasonable doubt.

ISSUE

Whether the trial court erred in convicting the accused-appellant of murder based on the evidence presented.

RULING

The Supreme Court affirmed the conviction. The Court found the testimonies of the prosecution witnesses, Evelyn Paras and Edgardo Castro, to be credible, straightforward, and consistent. They positively identified the appellant as the assailant who attacked the victim from behind without warning. This manner of attack constituted treachery (alevosia), which qualified the killing as murder. The autopsy report corroborated the witnesses’ accounts, detailing fatal stab wounds to the victim’s back.
The defense of alibi was correctly rejected. For alibi to prevail, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of his being at the crime scene. The appellant’s house was merely thirteen meters away, rendering his presence at the scene entirely possible. Alibi cannot prevail over the positive identification by credible witnesses. The Court also noted that any alleged irregularity in the appellant’s arrest was waived when he voluntarily submitted to the trial court’s jurisdiction by entering a plea and participating in the trial. The award of civil indemnity was proper, though the actual damages for funeral expenses were slightly reduced to conform to the evidence. The decision of the trial court was affirmed with this modification.