G.R. No. 127761; April 28, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PEDRO R. PASCUAL, accused-appellant.

FACTS

The accused-appellant, Pedro R. Pascual, was charged with Murder for the killing of Dr. Maximino P. Picio, Jr. on March 14, 1995, in San Manuel, Isabela. The prosecution’s case rested primarily on the eyewitness account of Marissa Robles, a former midwife. She testified that around 9:00 PM, as Dr. Picio was about to drive home from her house, two armed men approached. One assailant shoved her aside, and both men fired repeatedly at Dr. Picio despite his pleas. The victim was pulled from his vehicle and shot further while on the ground. Robles positively identified Pascual as one of the gunmen, recognizing him due to electric light, the vehicle’s headlights, and moonlight. She stated she had seen him at the Rural Health Unit a week prior.
The defense interposed alibi and denial. Pascual claimed he was at his home in Barangay Eden, San Manuel, entertaining neighbors until past 10:00 PM on the night of the crime. He asserted he was arrested without cause the next day and highlighted that a paraffin test yielded a negative result for gunpowder nitrates on his hands. He denied any acquaintance with the victim.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt, specifically concerning the credibility of the eyewitness identification and the sufficiency of evidence to overcome the defense of alibi.

RULING

The Supreme Court affirmed the conviction. The Court found the eyewitness identification by Marissa Robles to be credible and reliable. The conditions of illumination at the crime scene—from an electric post, vehicle headlights, and moonlight—were sufficient for a clear view. Her prior, albeit brief, encounter with the appellant a week earlier provided a basis for recognition, making her identification not a product of mere afterthought. The positive and categorical testimony of a credible eyewitness prevails over alibi and denial, which are inherently weak defenses.
The Court dismissed the negative paraffin test as inconclusive, noting it is not determinative of innocence as nitrates can be removed by washing. The established facts demonstrated the qualifying circumstance of treachery (alevosia), as the attack was sudden and deliberate, rendering the victim defenseless. The trial court’s assessment of witness credibility was accorded great respect. The penalty of reclusion perpetua was affirmed. The civil indemnity was modified, awarding P50,000 as civil indemnity, P50,000 as moral damages, and P832,026 for loss of earning capacity, computed based on the victim’s age and proven income.