GR 112982; (December, 1995) (Digest)
G.R. No. 112982 . December 29, 1995.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GERUNDIO PRADO, alias “ERIC”, accused-appellant.
FACTS
Accused-appellant Gerundio Prado, along with three others, was charged with the murder of Barangay Captain Severino Aquino, Jr. The prosecution established that on July 21, 1992, the victim attended a birthday party where a heated argument ensued between him and the Prado cousins. After leaving the party, the victim was waylaid. Eyewitnesses Cornelio Aquino and Eduardo Macam testified that they saw the victim being mauled by co-accused Luis Prado, Oscar Prado-Posadas, and Brigido Prado. As the victim struggled to stand up, appellant Gerundio Prado emerged and shot him with a long firearm. The victim later died from his wounds. Before his death, he identified appellant as the shooter to his sisters.
The defense interposed denial and alibi. Co-accused claimed they left the party together and returned to Manila, while Brigido Prado denied being present. Appellant Gerundio Prado did not testify. The trial court acquitted the three co-accused but convicted appellant Gerundio Prado of murder, sentencing him to reclusion perpetua.
ISSUE
Whether the trial court erred in convicting accused-appellant Gerundio Prado of murder based on the evidence presented.
RULING
The Supreme Court affirmed the conviction. The legal logic centered on the strength of the prosecution’s evidence against the weak defense of alibi. The positive identification by two eyewitnesses, who had no ill motive to falsely testify, was deemed credible and sufficient to establish appellant’s guilt beyond reasonable doubt. The Court emphasized that alibi is inherently weak and cannot prevail over positive identification, especially when the appellant was seen at the scene of the crime. The recovery of the firearm used in the shooting, linked to the appellant, further corroborated his culpability. The qualifying circumstance of treachery was correctly appreciated, as the attack was sudden and rendered the victim defenseless after the mauling. The trial court’s factual findings, particularly on witness credibility, are accorded great respect and were found to be supported by the evidence. Thus, no reversible error was committed.