G.R. No. 110103, August 4, 1994
People of the Philippines vs. Ruperto San Gabriel

FACTS

On the evening of July 27, 1989, Rolando Rodela was drinking coffee inside his mother’s house in Meycauayan, Bulacan. The house was illuminated by a fluorescent lamp. His mother, Maria Areglo Rodela, was in the kitchen about a meter away, and his sister, Teresita Rodela, was at the terrace. The assailant passed Teresita, entered the house, and repeatedly stabbed Rolando, who sustained fatal wounds. Both Maria and Teresita witnessed the attack and positively identified the assailant as Ruperto San Gabriel, a close friend of the victim and a first cousin of the victim’s wife. Rolando was pronounced dead at the hospital due to massive hemorrhage. Ruperto San Gabriel was later apprehended in Mindoro.
The accused-appellant, Ruperto San Gabriel, pleaded not guilty and interposed the defense of alibi. He claimed that from 1971 until his arrest in 1989, he had been residing in Mindoro, overseeing his mother’s fishpond. He specifically asserted that on the night of the crime, he and his brother-in-law were fishing in Naujan, Oriental Mindoro, which is hundreds of kilometers away from the crime scene. His brother-in-law corroborated this testimony. The trial court rejected this defense.

ISSUE

Whether the trial court erred in convicting the accused-appellant of murder based on the positive identification by the prosecution witnesses, despite his defense of alibi.

RULING

The Supreme Court affirmed the conviction but modified the civil indemnity. The trial court’s assessment of witness credibility is accorded great weight and respect, as it was in the best position to observe the witnesses’ demeanor. The positive identification by two eyewitnesses, Maria and Teresita Rodela, who knew the accused-appellant well as a childhood mate and relative, was categorical and consistent. They testified under a lighted condition and from close proximity, leaving no doubt about their identification.
The defense of alibi cannot prevail over this positive identification. For alibi to succeed, the accused must demonstrate not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to have been at the scene. The accused-appellant failed to conclusively prove such impossibility. Furthermore, the absence of ill-motive is inconsequential when there is direct and positive evidence of the accused’s commission of the crime. The attack was sudden, rendering the victim unable to defend himself, which constituted treachery and qualified the killing as murder. The Court, however, reduced the civil indemnity from P100,000 to P50,000 in accordance with prevailing jurisprudence at the time.