G.R. No. 110600 August 7, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LEODEGARIO RAMOS, WILLY ANOVA and NILO ALFARO, accused-appellants.

FACTS

Accused-appellants Leodegario Ramos and Nilo Alfaro, along with Willy Anova (at large), were charged with Murder for the killing of Bienvenido de la Cruz on December 26, 1987, in Occidental Mindoro. The prosecution presented eyewitness Nelia Denila, who testified that she saw the three accused attack the victim: Ramos stabbed him while Anova held him, Alfaro also stabbed him, and Anova hacked him with a bolo, after which Ramos took the bolo and hacked the fallen victim. The victim’s daughter, Delia Fetalver, and wife, Leonora de la Cruz, provided corroborative testimonies. Leonora stated that the three accused, armed with bolos and a knife, came looking for her son Danilo and her husband, the victim, earlier that evening. She last saw the victim walking away with the three accused towards the location where his body was later found.
The defense consisted of alibis. Ramos claimed he was at home cooking, while Alfaro asserted he was preparing food for his children’s baptism the next day. Their respective wives corroborated these accounts. A quack doctor, Desabilita Dawis, testified that eyewitness Nelia Denila was being treated at her house during the time of the crime, thereby challenging Denila’s presence at the scene. The trial court convicted Ramos and Alfaro of Murder, qualified by treachery, and sentenced them to reclusion perpetua. The Court of Appeals affirmed the conviction.

ISSUE

Whether the guilt of accused-appellants Leodegario Ramos and Nilo Alfaro for the crime of Murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimonies of prosecution witnesses, particularly eyewitness Nelia Denila, to be credible and consistent. Denila provided a clear and detailed account of the concerted attack by all three accused. The Court rejected the defense’s attempt to impeach her testimony through Desabilita Dawis, noting that Dawis’s testimony did not conclusively prove it was impossible for Denila to have witnessed the crime. The corroborative testimonies of the victim’s relatives, Delia Fetalver and Leonora de la Cruz, were also upheld. The Court ruled that the testimonies of relatives are generally credible, as they strive to remember the assailants’ identities.
The legal logic centered on the weakness of the defense of alibi against positive identification. For alibi to prevail, the accused must demonstrate it was physically impossible for them to be at the crime scene. Appellants failed to do this, as they admitted being in the same municipality that evening. The killing was properly qualified as Murder under Article 248 of the Revised Penal Code due to the presence of abuse of superior strength, as three armed men attacked a single, unarmed victim. The Court found no reason to disturb the factual findings of the lower courts regarding witness credibility. The penalty of reclusion perpetua and an indemnity of Fifty Thousand Pesos to the victim’s heirs were affirmed.