GR 112858; (March, 1996) (Digest)
G.R. Nos. 112858-59 March 6, 1996
People of the Philippines vs. Ralphy Alcantara and Andres Jose y Geronimo a.k.a. Boy Jose
FACTS
On February 15, 1989, former Mayor Jeremias Villanueva and his security, Pat. Virgilio Lascano, were fatally shot by assailants using M-16 and M-14 rifles in Las Piñas. Eyewitnesses Apolinario Dimaano and Lilibeth Malinis saw the attack, which occurred in broad daylight. Initially, the witnesses did not identify the perpetrators. Following a raid on a Parañaque safehouse on March 16, 1989, based on confidential information, police apprehended appellant Ralphy Alcantara, a patrolman, and recovered high-powered firearms and a blue Toyota Corolla. Subsequently, both witnesses positively identified Alcantara from a lineup and the car used in the shooting. Dimaano also identified Alcantara and another individual, Teodulo Batino, as the gunmen.
Appellants Alcantara and Andres Jose were charged with two counts of Murder. The trial court acquitted several co-accused for insufficient evidence but convicted Alcantara and Jose. The court found conspiracy based on the witnesses’ accounts and the circumstances. The appellants appealed, challenging the credibility of the witnesses and the finding of conspiracy, and interposing alibi as their defense.
ISSUE
Whether the prosecution proved the guilt of appellants Ralphy Alcantara and Andres Jose for the crime of Murder beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The positive identification by eyewitnesses Dimaano and Malinis, who witnessed the crime in clear daylight, prevails over the defenses of alibi and denial. The Court upheld the trial court’s assessment of witness credibility, noting that minor inconsistencies in their testimonies did not detract from their core narrative, which was consistent on material points. The Court also affirmed the finding of conspiracy. The coordinated actions of the assailants—arriving together, simultaneously firing at the victims, and fleeing together—demonstrated a unity of purpose and design to commit the killings.
The appellants’ alibis were properly rejected. For alibi to prosper, it must be shown that it was physically impossible for the accused to be at the crime scene. Alcantara claimed to be at the Western Police District headquarters in Manila, and Jose claimed to be at home in Taguig, both locations being merely minutes away from Las Piñas. This did not constitute physical impossibility. The collective evidence, including the positive identification and the establishment of conspiracy, sufficiently proved their guilt beyond reasonable doubt.