G.R. Nos. 116224-27; March 28, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. DONATO CARAIG, appellant.

FACTS

Appellant Donato Caraig was charged with three counts of murder and one count of frustrated murder. The charges stemmed from a shooting incident in the early morning of October 5, 1988, in Quezon City. The prosecution’s case, primarily through eyewitness Edmundo Diaz, established that after a brief altercation at the Orchids Beerhouse, Caraig and his cohorts chased the victims’ taxi. They blocked the vehicle, alighted, and fired upon the passengers with .45 caliber pistols, killing Melencio Castro Jr., Roberto Raagas, and Placido Agustin, and wounding Diaz, who survived by playing dead. This account was corroborated by another eyewitness, Danilo Javier.
The defense presented an alibi, with Caraig claiming he was in Cavite at the time of the incident, supported by testimonies from his wife and a friend. The trial court rejected this defense, giving greater weight to the positive identification by the prosecution witnesses. It found Caraig guilty beyond reasonable doubt of all charges, sentencing him to reclusion perpetua for each murder count and an indeterminate penalty for frustrated murder, plus civil liabilities.

ISSUE

The core issue is whether the prosecution proved the guilt of appellant Donato Caraig beyond reasonable doubt for the crimes of murder and frustrated murder.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, emphasizing that the positive identification of Caraig by two eyewitnesses, who had no ill motive to testify falsely, prevails over the weak defense of alibi. The Court found the alibi unpersuasive as Caraig failed to prove it was physically impossible for him to be at the crime scene. The distance between Cavite and Quezon City did not preclude his presence.
Regarding the qualifying circumstances, the Court affirmed the presence of treachery. The attack was sudden and deliberate, employing a hail of gunfire upon the helpless victims inside a taxi, ensuring the execution without risk to the assailants. This method directly and specifically ensured the victims had no opportunity to defend themselves. However, the Court deleted the finding of evident premeditation for lack of conclusive proof of the requisite planning and time to reflect. The crimes were thus properly qualified as murder by treachery alone. The penalties and awards for damages were modified in accordance with prevailing jurisprudence, with civil indemnity affirmed and moral damages adjusted.