G.R. No. 125311 March 17, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ONYOT MAHINAY and QUIRINO CAÑETE, accused, QUIRINO CAÑETE, accused-appellant.

FACTS

Accused-appellant Quirino Cañete was charged with Murder for the killing of Manolo Mission. The prosecution evidence established that during a barangay fiesta dance in Mabinay, Negros Oriental, an argument ensued between Cañete and the victim. Later, while Manolo Mission was walking home, he was followed by Cañete. They argued again, at which point Cañete’s co-accused, Onyot Mahinay, suddenly stabbed Mission from behind. As the wounded victim attempted to flee, Cañete himself pursued and stabbed Mission on the chest and the right side of his body. Eyewitnesses Joel Mission, Roman Bucog, and Jose Mait consistently testified to seeing Cañete’s direct participation in the attack. The victim died from multiple stab wounds.
The defense interposed denial, with Cañete claiming he was merely present in the vicinity but did not participate. He asserted an alibi, claiming he was in Bukidnon at the time and only arrived in Mabinay on the afternoon after the crime. The trial court found the testimonies of the prosecution witnesses credible and convicted Cañete of Murder, sentencing him to reclusion perpetua.

ISSUE

Whether the trial court erred in convicting accused-appellant Quirino Cañete of Murder based on the evidence presented.

RULING

The Supreme Court affirmed the conviction. The Court found no reason to disturb the trial court’s assessment of witness credibility, noting that the testimonies of Joel Mission, Roman Bucog, and Jose Mait were consistent, straightforward, and corroborative of each other on material points. Their positive identification of Cañete as a direct assailant who stabbed the victim prevailed over his weak defense of denial and alibi. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but that it was physically impossible for him to have been at the scene. Cañete failed to establish such physical impossibility. The Court agreed with the qualifying circumstance of treachery (alevosia). The attack was sudden and unexpected, with the initial stab from behind by Mahinay ensuring the victim had no opportunity to defend himself. Cañete’s subsequent stabbing of the already wounded and fleeing victim continued this treacherous mode of attack. The Court, however, found the evidence insufficient to prove evident premeditation. The penalty of reclusion perpetua and the award of civil indemnity were thus affirmed.