G.R. No. 116748 June 2, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARJORIE CASTILLO, accused-appellant.

FACTS

Accused-appellant Marjorie Castillo was charged with the complex crime of murder with frustrated murder. The information alleged that on November 27, 1990, in Surallah, South Cotabato, Castillo, armed with a shotgun and with companions, willfully attacked Elma Baulite and her one-year-old daughter Gemma Baulite. Castillo fired once, hitting Gemma in the abdomen, causing her death, and hitting Elma in the arm. The crime was qualified by abuse of superior strength and committed at the dwelling of the offended party. During trial, prosecution witness Elma Baulite testified that Castillo, carrying a shotgun and claiming to be an NPA member, called for her husband from outside their house, pointed the gun, and threatened them. When Elma went down carrying Gemma, Castillo shot them at close range. Their neighbor, Eliodoro Pueblo, heard the shot and cries for help, assisted the victims, and brought Elma to the hospital (Gemma was already dead). The defense was alibi, with Castillo claiming he was in General Santos City looking for work and staying with his friend Rene Cuenca Feria at the time of the incident, supported by testimonies from Feria and Castillo’s brother. The trial court convicted Castillo, finding the killing qualified by abuse of superior strength, and sentenced him to reclusion perpetua, plus indemnities.

ISSUE

Whether the trial court erred in convicting the accused-appellant based on the credibility of the prosecution witness and in rejecting the defense of alibi.

RULING

The Supreme Court affirmed the conviction. The Court held that the trial court’s assessment of witness credibility is entitled to great weight and respect, as it is in a better position to observe demeanor. The Court found the testimony of Elma Baulite to be sincere, direct, and convincing, and her positive identification of Castillo as the perpetrator was categorical. The Court rejected the defense’s arguments regarding improbabilities in Elma’s actions (e.g., going down the house), explaining that people react differently to startling situations, and such acts could be attributed to curiosity or the “usisero” trait. The Court also noted the absence of any improper motive for Elma to falsely testify. The defense of alibi was properly rejected as it was not physically impossible for Castillo to be at the crime scene, and it was inherently weak against positive identification. The crime was properly qualified as murder due to abuse of superior strength. The penalty of reclusion perpetua and the awarded indemnities were affirmed.