G.R. No. 111806; March 9, 2000
People of the Philippines vs. Benjamin Galano y Gloria, Brigido Tripoli y Cabilosa, and Romulo Sta. Iglesia y Cuison

FACTS

On September 8, 1990, brothers Virgilio and Leonardo Torres were waiting for a ride on España Street in Manila when they heard a shout of “snatcher.” They approached the person who shouted. Shortly after, a jeepney arrived. Appellant Benjamin Galano alighted, chased the shouting person, and then returned. Subsequently, appellants Brigido Tripoli and Romulo Sta. Iglesia exited the same jeepney, grabbed the Torres brothers from behind, and held them. Benjamin Galano then appeared and stabbed both Virgilio and Leonardo in the stomach. The assailants fled in the jeepney. Leonardo died from his wounds, but Virgilio survived, noted the jeepney’s plate number (CBR 522), and later positively identified all three appellants in a police line-up.
The appellants interposed the defenses of alibi and denial. Benjamin claimed he was a passenger on a stoned jeepney that night, while Brigido and Romulo asserted they were watching a movie in Morayta. The Regional Trial Court convicted them of Murder qualified by treachery and sentenced them to reclusion perpetua. Their co-accused, Elmer Honorio, was acquitted.

ISSUE

Whether the guilt of appellants Benjamin Galano, Brigido Tripoli, and Romulo Sta. Iglesia for the crime of Murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimony of surviving victim Virgilio Torres to be clear, credible, and consistent. His positive identification of the appellants, whom he observed at close range during the well-lit incident, prevailed over the weak defenses of alibi and denial. For alibi to prosper, the accused must prove not only their presence elsewhere but also the physical impossibility of being at the crime scene. Appellants failed to do so, as the places they cited (Morayta, Quiapo) were not far from España Street. The Court upheld the finding of treachery (alevosia). The attack was sudden and from behind, with the victims being held by Brigido and Romulo, rendering them unable to defend themselves. This method of execution ensured the assailants’ safety from any retaliation. The qualifying circumstance of evident premeditation was correctly disregarded for lack of proof of planning. The penalty of reclusion perpetua was affirmed, and appellants were ordered to pay P50,000.00 as civil indemnity to the heirs of Leonardo Torres.