G.R. No. 108773 August 15, 1994
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JESUS JIMENEZ, JULIAN JIMENEZ and GERMAN JIMENEZ, accused, JULIAN JIMENEZ, appellant.

FACTS

Accused Jesus Jimenez, German Jimenez, and Julian Jimenez were charged with Murder for the killing of Eustaquio Bacarro on September 14, 1983, in Barangay Lanas, Naga, Cebu. Jesus and German were tried separately, found guilty, and sentenced to reclusion perpetua, which they did not appeal. Julian Jimenez was later arrested and tried separately. The prosecution’s main witness was Valeriana Rivera, who testified that she, along with Heracleo Arabis and his wife Clarita, were walking home from a fiesta at around 2:00 a.m. when they heard a shout for help. They approached and saw the victim kneeling before Jesus Jimenez, pleading for mercy. Jesus struck the victim with a stone, followed by German, and then accused-appellant Julian Jimenez, who also struck the victim with a stone at least twice until Jesus stated the victim was already dead. The trial court found Julian Jimenez guilty beyond reasonable doubt of Murder and sentenced him to reclusion perpetua and indemnity of P10,000 to the heirs of the victim. Julian Jimenez appealed, challenging the credibility of the prosecution witness and the sufficiency of the evidence.

ISSUE

1. Whether the trial court erred in convicting accused-appellant based on the uncorroborated, biased, and highly doubtful testimony of prosecution witness Valeriana Rivera.
2. Whether the trial court erred in not giving probative value to the testimonies of the accused and his witnesses.
3. Whether the trial court erred in finding accused Julian Jimenez guilty beyond reasonable doubt of the crime of murder.

RULING

The Supreme Court AFFIRMED the trial court’s decision with modification. The Court held:
1. The alleged inconsistencies in Valeriana Rivera’s testimony were minor and did not impair her credibility. The discrepancy regarding whether accused-appellant struck the first or last blow was insignificant, as her positive and categorical identification of him as one of the assailants remained clear. Inconsistencies on minor matters do not damage a witness’s credibility. Her familiarity with accused-appellant, being a former neighbor and relative by marriage, bolstered the reliability of her identification. The claim that her testimony about an electric bulb illuminating the scene was refuted was not sustained, as the defense witness admitted he did not know if the area was energized by another cooperative or if the nearby school had electricity at the time. The testimony of a single credible witness is sufficient for conviction.
2. The defense of alibi presented by accused-appellant, claiming he was out fishing, cannot prevail over the positive identification by the prosecution witness. Alibi is inherently weak and unreliable, especially when contradicted by direct eyewitness testimony.
3. The trial court’s findings of fact, particularly on witness credibility, are generally accorded great weight and respect on appeal, as the trial judge is in the best position to observe witness demeanor. No compelling reason was shown to overturn these findings. The Court thus upheld the conviction for Murder but increased the civil indemnity to P50,000.00.