G.R. No. 136745 ; November 15, 2000
PEOPLE OF THE PHILIPPINES, appellee, vs. RESTITUTO RENDAJE, appellant.

FACTS

The prosecution established that on August 6, 1994, in Dingle, Iloilo, appellant Restituto Rendaje, armed with a bladed weapon, stabbed to death fifteen-year-old deaf-mute Lennie Rendon in a sugarcane field. The victim’s sister, Lodelyn Rendon, testified that she saw appellant following Lennie that morning. The victim was later found dead with multiple stab wounds. Eduardo Gorantes, a companion of appellant, testified that he saw appellant wet and alone near the crime scene shortly after the incident, with appellant claiming he took a shortcut through the sugarcane field. The medico-legal report detailed eight stab wounds, abrasions, and a hematoma, indicating a violent attack.
The defense presented an alibi, claiming appellant was at a healing ritual in a different barangay at the time of the killing and could not have been at the crime scene. Appellant denied the charges and implicated another person. The trial court, however, found the testimonies of the prosecution witnesses credible and convicted appellant of murder qualified by treachery, sentencing him to reclusion perpetua and ordering him to pay damages.

ISSUE

The core issue is whether the trial court erred in convicting appellant of murder based on the evidence presented, despite his defense of alibi and denial.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the assessment of witness credibility is best left to the trial court, which has the unique opportunity to observe the witnesses’ demeanor and conduct on the stand. The testimonies of Lodelyn Rendon and Eduardo Gorantes were found to be clear, consistent, and credible, positively identifying appellant as the perpetrator. Their accounts were corroborated by the physical evidence and the medico-legal findings.
The Court rejected appellant’s alibi as inherently weak. For an alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but that it was physically impossible for him to have been at the crime scene. Appellant failed to establish such physical impossibility, as the distance between the healing ritual and the crime scene was not insurmountable. Denial, like alibi, cannot prevail over positive identification. The qualifying circumstance of treachery was correctly appreciated, as the attack was sudden and deliberate against a defenseless deaf-mute victim, ensuring the execution without risk to the appellant. The penalty of reclusion perpetua and the awarded damages were sustained.