G.R. No. 123069 March 1, 2001
People of the Philippines vs. Pedro Saspa, Rafael Sumiling, and Juan Saha

FACTS

Accused-appellants Pedro Saspa and Rafael Sumiling, along with Juan Saha, were charged with Murder for the killing of Isidro Hayo. The prosecution evidence, primarily from eyewitness Thelma Hayo (the victim’s wife), established that on April 26, 1986, the accused, who were members of the Civilian Home Defense Front (CHDF), summoned Isidro from his house. They then hogtied him, brought him to a nearby cockpit, and shot him multiple times. Thelma witnessed the initial arrest and shooting. Sulpicio Hayo, the victim’s father, testified he heard gunshots and later saw from a distance several men in fatigue uniforms hacking his son’s neck. Casiano Cuevas, another witness, saw appellants and others in uniforms carrying firearms near the crime scene that morning.
The defense interposed alibi. Appellants claimed that on the same morning and time, they were part of a CHDF unit escorting civilians three kilometers away in Double Hauling, where they were ambushed by the New People’s Army (NPA). They asserted that a firefight ensued, resulting in the death of their comrade Alfredo Untal, and that they spent the remainder of the day attending to his body, making it impossible for them to be at the crime scene.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellants beyond a reasonable doubt, overcoming their defense of alibi.

RULING

The Supreme Court affirmed the conviction. The positive identification by eyewitness Thelma Hayo, who knew the appellants and had no ill motive to falsely testify, was found credible and sufficient to establish their presence and participation in the crime. The Court emphasized that alibi is inherently weak and cannot prevail over positive identification. For alibi to prosper, the accused must demonstrate not only their presence elsewhere but also the physical impossibility of being at the crime scene. Appellants failed to prove this impossibility, as the distance of three kilometers between the alleged ambush site and the crime scene did not preclude their ability to be present at the murder. The trial court’s assessment of witness credibility is accorded great respect. However, the Court modified the penalty by disallowing the aggravating circumstances of band and ignominy due to insufficient proof. The penalty was properly imposed at reclusion perpetua, the medium period of the penalty for murder absent any aggravating or mitigating circumstances. The award of civil indemnity was sustained.