G.R. No. 119332 August 29, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JACK SORREL y VILLAR, accused-appellant.

FACTS

On November 7, 1988, businessman Teofilo Geronimo was shot and killed during a robbery along Paterno Street in Manila. The prosecution’s case rested primarily on the eyewitness account of Benito de la Cruz, who testified that he saw appellant Jack Sorrel, along with two companions, accost Geronimo. De la Cruz, from a distance of about four meters, heard Sorrel demand Geronimo’s bag and threaten to kill him if he refused. When Geronimo held onto his clutch bag, Sorrel shot him in the head, took the bag, and walked away with his companions. De la Cruz later identified Sorrel from a newspaper photo and subsequently pointed him out in a police lineup at the Quezon City jail. The prosecution also presented evidence that Geronimo had just withdrawn P40,000 from a bank minutes before the incident.
The defense interposed denial and alibi. Sorrel claimed he was attending a family reunion in Quezon City at the time of the crime. He alleged that he was illegally arrested and tortured by police into confessing. He further argued that the testimony of Benito de la Cruz was not credible, suggesting de la Cruz was a “professional witness” due to his alleged involvement in another case. The trial court convicted Sorrel of the special complex crime of robbery with homicide and sentenced him to reclusion perpetua.

ISSUE

The core issue is whether the prosecution proved Sorrel’s guilt for robbery with homicide beyond reasonable doubt, particularly in light of the defense’s challenge to the credibility of the eyewitness and its presentation of alibi.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the eyewitness testimony as credible and sufficient to establish guilt beyond reasonable doubt. The Court found no ill motive for Benito de la Cruz to falsely testify against Sorrel. His detailed account of the event, including the demand for the bag and the shooting, was consistent and remained unshaken on cross-examination. His subsequent identification of Sorrel from a newspaper photo and in a police lineup was deemed reliable. The Court emphasized that the evaluation of witness credibility is best performed by the trial court, and its findings are generally binding on appeal.
The defense of alibi was correctly rejected. For alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of his being at the crime scene. Sorrel failed to prove this impossibility, as Quezon City is not so geographically distant from Manila as to preclude his presence at the crime scene. Furthermore, alibi is inherently weak and cannot prevail over the positive identification by a credible witness. The Court also dismissed the defense’s attempt to discredit de la Cruz by labeling him a “professional witness,” noting that a prior conviction, even for perjury, does not automatically disqualify a person from testifying or render his testimony incredible. The trial court’s award of damages, including P40,000 as restitution for the stolen money and P30,000 for funeral expenses, was also affirmed as substantiated by the evidence.