GR 114382; (July, 1995) (Digest)
G.R. No. 114382 July 20, 1995
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ESTEBAN ACOB, CRIZALDY ACOB alias “ZALDY” and ROBINSON SILAO, accused-appellants.
FACTS
On the evening of March 27, 1986, in Barangay Curifang, Solano, Nueva Vizcaya, an altercation ensued after Crizaldy “Zaldy” Acob, who was drunk, confronted Manolo Reyes about a debt. Zaldy later returned with companions, including Esteban Acob and Robinson Silao, and began shouting threats and throwing stones at the Reyes residence. Marlon Reyes eventually came out, whereupon Robinson Silao held him, Zaldy Acob struck his head with a stone, and Esteban Acob hit his eye with a fishing dart. The attack ceased only after a CHDF member fired warning shots.
The gravely injured Marlon Reyes was rushed to the hospital but later died from his head injuries. Prosecution witnesses Gloria Cadorna and Rodrigo Julio positively identified the appellants as the assailants. The appellants raised the defense of alibi, claiming they were in their respective homes during the incident.
ISSUE
Whether the trial court erred in convicting the accused-appellants of murder based on the testimonies of the prosecution witnesses and in rejecting their defense of alibi.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the credibility of prosecution witnesses Gloria Cadorna and Rodrigo Julio, whose direct eyewitness accounts of the assault were found consistent and credible. The Court emphasized that factual findings of the trial court on witness credibility are accorded great respect and are not to be disturbed on appeal absent a clear showing of oversight or misappreciation.
The Court dismissed the appellants’ challenge to the testimony of tricycle driver Randy Pataweg, noting it was merely corroborative and unnecessary for conviction given the strong positive identification by the eyewitnesses. The defense of alibi was correctly rejected. For alibi to prosper, the accused must demonstrate the physical impossibility of their presence at the crime scene. The appellants failed to do so, as their houses were established to be near the locus criminis. Moreover, alibi cannot prevail over the positive identification of the accused by credible witnesses. The Court found no reversible error in the trial court’s judgment.