G.R. No. 119013 March 6, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALEX OLIANO y PUGONG and GABRIEL CALIAG, accused, ALEX OLIANO y PUGONG, accused-appellant.

FACTS

An Information was filed accusing Alex Oliano and Gabriel Caliag of the murder of Benjamin Matias on March 16, 1987, in Sta. Fe, Nueva Vizcaya, committed with treachery, evident premeditation, and with the use of an illegally possessed firearm. Both pleaded not guilty. During trial, Caliag died, leading to the dismissal of the case against him. The trial court convicted Oliano of murder and sentenced him to reclusion perpetua, ordering him to pay damages to the victim’s heirs. Oliano appealed.
The prosecution’s version, primarily through the testimony of the victim’s widow Rosita Matias, is that on the night of March 16, 1987, after attending a wedding, she and her husband Benjamin were walking home. When they were about a meter away from two boulders on the road, Benjamin was shot from behind. Rosita saw appellant Alex Oliano behind the boulders holding a rifle and accused Gabriel Caliag behind a banana plant. The night was bright, enabling her to recognize them. She confronted Oliano at a neighbor’s house later, where he cried in response. The autopsy confirmed the victim died from a gunshot wound to the heart.
The defense presented an alibi. Oliano claimed he left the wedding with his family around 11:00 PM, arrived home by 11:30 PM, and was asleep until policemen awakened him around 2:00 AM. A pastor testified that paraffin tests on both accused were negative and that Caliag had a visual defect. The defense also suggested the scene was too dark for clear identification.

ISSUE

The core issue is whether the prosecution proved the guilt of accused-appellant Alex Oliano for the crime of murder beyond reasonable doubt, particularly concerning the credibility of the eyewitness testimony and the defense of alibi.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s findings on the credibility of the prosecution eyewitness, Rosita Matias. It found no reason to deviate from the rule that trial court assessments on witness credibility are binding unless facts of substance were overlooked. The Court found her testimony clear, consistent, and credible. She had a clear view of the appellant under a bright moonlit night and was familiar with him as a neighbor. Her immediate and spontaneous identification of Oliano at the neighbor’s house bolstered her credibility.
The defense of alibi was rejected as weak and unconvincing, especially in the face of positive identification. The negative paraffin test was deemed inconclusive, as it does not prove innocence. The claim of poor visibility was contradicted by the witness’s ability to see and recognize the assailants. The Court found the killing attended by treachery, as the victim was shot from behind without any opportunity to defend himself, qualifying the crime as murder. The penalty of reclusion perpetua and the award of damages were affirmed.