G.R. No. 132214 ; August 1, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ZALDY CASINGAL, accused-appellant.

FACTS

The accused-appellant, Zaldy Casingal, was charged with Murder and Illegal Possession of Firearm for the shooting death of Diosdado Palisoc on election night, May 8, 1995. Prosecution eyewitness Edgardo Mula Cruz testified that while waiting for the victim near a school gate, he heard a gunshot. Upon turning, he saw Palisoc facing the accused and falling to the ground. Cruz, who was seven meters away in a lighted area and knew the accused personally, saw Casingal holding a carbine before fleeing towards a house. The victim died from a gunshot wound. Ballistic tests confirmed that the slug and cartridge from the scene matched a carbine later found in that house, and paraffin tests on Casingal and the firearm were positive.
The defense, presented solely through Casingal, admitted his presence but claimed a certain Ernesto Payaoan was the triggerman. He alleged Payaoan instructed him to clean and test-fire the carbine, revealed an intent to kill Palisoc, and later shot the victim before passing the gun to him. Casingal executed conflicting affidavits recanting his story. Payaoan, presented in rebuttal, provided alibi evidence supported by a certification placing him on official election duty in another province at the time. A police officer also denied Casingal’s claim of having confessed Payaoan’s guilt to him.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Zaldy Casingal was the perpetrator of the murder, given the defense of denial and his attribution of the crime to another.

RULING

The Supreme Court affirmed the conviction for Murder. The ruling hinges on the credibility of the eyewitness account versus the accused’s inherently weak defense. The Court found the testimony of Cruz to be clear, credible, and consistent. He had a direct and unobstructed view of the incident from a short distance under sufficient lighting and positively identified Casingal, whom he knew. This positive identification prevails over Casingal’s bare denial and shifting alibi. His defense was further dismantled by the physical evidence: the ballistic match conclusively linked the murder weapon to the crime scene, and the paraffin findings corroborated his contact with a fired firearm.
The Court rejected Casingal’s claim implicating Payaoan as uncorroborated and improbable. Payaoan’s credible alibi, backed by documentary evidence, was directly contradicted by Casingal’s own vacillating affidavits, which severely damaged his credibility. The defense failed to show any ill motive for Cruz to falsely testify. Where there is no evidence that the principal witness was actuated by improper motive, his testimony is entitled to full faith and credit. Thus, the totality of the prosecution evidence established Casingal’s guilt beyond reasonable doubt. The illegal possession charge was absorbed by the murder conviction under the prevailing law at the time.