G.R. No. 126027 February 18, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BUENAVENTURA BATIDOR alias “TORA,” accused-appellant.

FACTS

The prosecution established that on the evening of January 2, 1995, accused-appellant Buenaventura Batidor shot and killed Donato Asis. The victim’s widow, Maria Lourdes Asis, testified that while she and her husband were having supper inside their house, she heard a gunshot. She turned towards the source and saw Batidor through the kitchen railing, immediately after which her husband fell, fatally wounded. The prosecution also presented Bienvenido Pagutlan, a neighbor, who testified that the following morning, Batidor, when informed of the victim’s death, callously replied, “patay lagi” (yes, he is dead).
The defense relied on denial and alibi. Batidor claimed he was at his brother’s house, approximately seven kilometers away, at the time of the shooting. He asserted he only learned of the incident the next morning from another person. To support his claim, he presented SPO2 Rolando Santiago, the investigating officer, whose testimony the trial court found did not corroborate the alibi but instead indicated the police investigation did not sufficiently rule out Batidor as a suspect.

ISSUE

Whether the testimony of a single eyewitness, the victim’s widow, is sufficient to sustain a conviction for murder beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction, reiterating that the credible testimony of a single witness is sufficient for a conviction if it meets the test of credibility. The Court found the testimony of Maria Lourdes Asis to be clear, convincing, and consistent. As an eyewitness who was present at the scene and who positively identified the appellant, her testimony was accorded full faith and credit. The Court noted that her relationship to the victim did not automatically impair her credibility; rather, it provided a strong motive for her to seek justice. Her account was straightforward and withstood rigorous cross-examination.
The defense of alibi was correctly rejected. 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 crime scene. Batidor failed to establish this impossibility, as the distance of seven kilometers was not insurmountable. Furthermore, alibi is inherently weak and cannot prevail over the positive and categorical identification by a credible eyewitness. The trial court’s assessment of witness credibility is entitled to great respect, as it had the direct opportunity to observe their demeanor. The Court found no reason to deviate from this finding. The conviction for murder and the penalty of reclusion perpetua were affirmed.