G.R. No. 128088 & 146639 January 31, 2001
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILSON RONAS, accused-appellant.

FACTS

Accused-appellant Wilson Ronas was charged with murder for the death of Mariano Buenaventura and frustrated murder for the wounding of Santiago Buenaventura. The prosecution alleged that on December 10, 1991, in San Manuel, Isabela, Ronas, with evident premeditation and treachery, shot the victims while they were inside a tent watching a duck farm. Santiago, who survived, testified that he recognized Ronas among the assailants due to the illumination from their flashlights. He stated that Ronas had a prior altercation with them over duck eggs. The victims were shot multiple times, resulting in Mariano’s death. Medical evidence confirmed the fatal nature of Mariano’s wounds and the non-fatal injuries sustained by Santiago.
For his defense, Ronas interposed an alibi, claiming he was at his grandmother’s wake, approximately one kilometer away, playing cards from the evening of December 9 until the early morning of December 10. He presented witnesses to corroborate his presence at the wake, though one stated Ronas left between 4:30 to 5:00 a.m. The Regional Trial Court convicted Ronas of both charges, prompting this appeal.

ISSUE

The primary issue is whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt, specifically overcoming his defense of alibi with positive identification.

RULING

The Supreme Court affirmed the conviction for murder but modified the conviction for frustrated murder to attempted murder. The Court upheld the trial court’s assessment of witness credibility, giving weight to Santiago Buenaventura’s positive identification of Ronas. Santiago had ample opportunity to recognize the accused, whom he knew personally, under the illumination of flashlights at a close distance. The Court found his testimony clear and consistent, detailing the prior motive and the sudden attack.
The defense of alibi was correctly rejected. For alibi to prevail, it must be demonstrated that the accused was so far away that he could not have been physically present at the crime scene. Ronas’s claimed location was only one kilometer away, which did not preclude his presence at the crime scene. His alibi, partly corroborated, was inherently weak and could not overcome the positive identification by the eyewitness. The Court also found the qualifying circumstance of treachery present, as the attack was sudden and unexpected, denying the victims any chance to defend themselves. The award of damages was modified in accordance with prevailing jurisprudence, deleting unsubstantiated actual damages and awarding temperate and moral damages accordingly.