G.R. No. 115687 February 17, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO QUILLOSA Y FORMANES, accused-appellant.

FACTS

On January 1, 1991, at around 5:00 AM, prosecution eyewitness Roberto Vasquez saw the victim, Ambrosio Ilocto, walking ahead of him on Santolan Road, Valenzuela. Suddenly, three men blocked the victim’s path. Appellant Reynaldo Quillosa held the victim’s right hand, a second man held his left hand, and a third man stabbed him three times. When the victim fell, appellant stated, “Leo that is enough, he would die,” after which all three fled. Vasquez testified he knew appellant by name as they were former neighbors. The victim was pronounced dead on arrival at the hospital.
The defense presented an alibi, with appellant claiming he was in Baliuag, Bulacan, during the incident, celebrating New Year with a friend, Buenaventura Jose, Jr. Appellant denied knowing the victim or the eyewitness. The Regional Trial Court convicted appellant of murder, qualified by treachery, and sentenced him to reclusion perpetua. Appellant appealed, challenging the eyewitness’s credibility, the rejection of his alibi, the medico-legal finding on the cause of death, and the appreciation of treachery.

ISSUE

Whether the trial court erred in convicting appellant of murder based on the eyewitness account, rejecting his alibi, and appreciating the qualifying circumstance of treachery.

RULING

The Supreme Court affirmed the conviction. On credibility, the Court upheld the trial court’s assessment, noting that minor inconsistencies in the eyewitness’s testimony on collateral matters did not undermine his core account of the crime, which was delivered in a straightforward and categorical manner. The positive identification by a credible witness prevails over a denial and alibi, which must be supported by clear and convincing evidence of the physical impossibility of the accused’s presence at the crime scene—a requirement not met here, as Baliuag, Bulacan, is not so far from Valenzuela as to preclude appellant’s presence.
Regarding the cause of death, the Court ruled that the medico-legal officer’s testimony—that death resulted from the piercing of the right lung by a broken rib caused by a stab wound—did not exculpate appellant. This detail merely specified the fatal mechanism of an injury inflicted during the concerted attack. Finally, the Court affirmed the presence of treachery. The attack was sudden, executed by three men who immobilized the unarmed victim by holding both his hands, thereby ensuring he could not offer any defense. This method deliberately and consciously adopted the means to accomplish the crime without risk to the assailants. The collective actions of the trio established conspiracy, making appellant equally liable for the fatal stabbing.