G.R. No. 132252; April 27, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JESUS MUYCO and ARNULFO MUYCO (at large), accused, JESUS MUYCO, accused-appellant.

FACTS

Accused-appellant Jesus Muyco and his cousin Arnulfo Muyco were charged with murder for the killing of Romeo Boteja Jr. on May 13, 1995. Only Jesus was apprehended. The prosecution evidence established that on the evening of the incident, Jesus, Arnulfo, the victim, and the victim’s uncle, Ernesto Boteja, were drinking under a mango tree. Suddenly, Arnulfo grabbed the victim’s hands, and while the victim struggled, Jesus stabbed him near the collarbone. Arnulfo then dragged the lifeless body to a sugarcane field, with Jesus following. Ernesto, shocked and immobilized by the event, fled only when he saw the accused returning. The victim’s body was found later that night.
Jesus Muyco denied involvement and interposed alibi, claiming he was in Passi, Iloilo, approximately fifty kilometers away, at the time of the killing. He was corroborated by two witnesses. The Regional Trial Court found him guilty of murder qualified by treachery, sentenced him to reclusion perpetua, and ordered him to pay indemnity and funeral expenses. He appealed, challenging the credibility of the eyewitness, the strength of the prosecution’s evidence, the rejection of his alibi, and the appreciation of treachery.

ISSUE

The core issue is whether the trial court erred in convicting Jesus Muyco of murder based on the eyewitness account of Ernesto Boteja, despite the defense of alibi and challenges to the witness’s credibility and the presence of treachery.

RULING

The Supreme Court affirmed the conviction. The positive identification by eyewitness Ernesto Boteja, who had no ill motive to testify falsely, prevails over the weak defense of alibi. The Court explained that alibi cannot succeed when the accused is positively identified and has not demonstrated it was physically impossible for him to be at the crime scene. The distance of fifty kilometers to Passi did not constitute such impossibility. Regarding witness credibility, the Court held that Ernesto’s shocked inaction during the stabbing was not unnatural, as there is no standard behavioral response to a startling event; his reaction was understandable. The alleged inconsistency between his testimony (stabbing on the neck) and the medical finding (wound near the collarbone) was inconsequential for a lay witness.
On the qualifying circumstance, the Court upheld the finding of treachery. The attack was sudden and unexpected, employing means that ensured the execution of the crime without risk to the assailants from any defense the victim could offer. The victim was held by Arnulfo and then fatally stabbed by Jesus, rendering him helpless. The Court also modified the damages, increasing the death indemnity to P50,000.00 and awarding P156,172.80 for loss of earning capacity, computed based on the victim’s age and income, despite the absence of documentary evidence, following prevailing jurisprudence.