GR 133541; (April, 2004) (Digest)
G.R. No. 133541; April 14, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. RICKY QUIMZON, appellant.
FACTS
The prosecution established that on March 7, 1992, at a benefit dance in Burauen, Leyte, the victim Marlo Casiong accidentally bumped appellant Ricky Quimzon, his cousin. Later, co-accused Salvacion Lacsarom invited Marlo outside the hall. Witnesses Emolyn Casiong and Rommel Redoña followed and saw Salvacion push Marlo towards a group including appellant, Canoto Cabero, and Edgardo Detona. Canoto and Edgardo stabbed Marlo. The wounded Marlo fled but was caught by appellant, who held his hands, rode on his back, and repeatedly stabbed him, leading to Marlo’s death.
Appellant interposed the defense of alibi, claiming he was in Barangay Patag, 18 kilometers away, attending a different dance at the time of the killing. He was corroborated by the barangay chairman and a councilor. He alleged his inclusion in the case was due to his refusal to testify for the prosecution.
ISSUE
The core issues were: (1) the sufficiency of the prosecution evidence to establish appellant’s guilt beyond reasonable doubt, and (2) the validity of his alibi defense.
RULING
The Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Emolyn Casiong credible, positive, and consistent, clearly identifying appellant as a direct participant who held the victim and delivered the fatal stab wounds. Her relationship to the victim did not impair her credibility; instead, it lent weight to her testimony as she would not accuse an innocent person. The defense of alibi was correctly rejected as inherently weak and unpersuasive. For alibi to prosper, the accused must prove not only his presence elsewhere but also the physical impossibility of being at the crime scene. Appellant failed to establish this impossibility, as the distance of 18 kilometers did not preclude his presence, especially absent clear proof of travel time and conditions. His alibi could not prevail over the positive identification by a credible eyewitness. The qualifying circumstance of treachery was properly appreciated, as the attack was sudden and deliberate, ensuring the victim had no opportunity to defend himself. The penalty of reclusion perpetua and the awarded damages were sustained.