G.R. No. 137610 -11; February 6, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MANUEL GUTIERREZ (at large); JUANCHO GUTIERREZ (at large); ESTING CARIÑO (at large) and ZACARIAS CASTILLO, accused-appellant.

FACTS

In the early morning of January 8, 1992, Lorenzo de Leon was driving a passenger jeep in Barangay Sanlibo, Bayambang, Pangasinan, carrying several family members and companions. While traversing a rough road, their vehicle was ambushed and repeatedly fired upon by four men. The attack resulted in the deaths of Vicente de Leon, Aldren de Leon, and Guillermo Tapiador, and caused serious gunshot injuries to Lorenzo de Leon, Catalina de Leon, Gregoria de Leon, and Racquel Agbuya. The prosecution presented eyewitnesses Lorenzo and Catalina de Leon, who positively identified the assailants as Zacarias Castillo, Esting Cariño, and the Gutierrez brothers. They testified that the jeep’s headlights and the approaching dawn illuminated the attackers, whom they recognized as residents of the same or adjacent barangays.
Accused-appellant Zacarias Castillo pleaded not guilty and interposed the defense of alibi, claiming he was at a different location attending to his carabao at the time of the incident. The trial court rejected his defense and found him guilty of three counts of murder and four counts of frustrated murder, sentencing him to reclusion perpetua for the murders. Castillo appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, primarily questioning the credibility of the eyewitness identifications.

ISSUE

Whether the prosecution successfully proved the guilt of accused-appellant Zacarias Castillo for the crimes of murder and frustrated murder beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction with modification. The Court upheld the trial court’s assessment of the credibility of the prosecution witnesses, Lorenzo and Catalina de Leon. Their positive identification of Castillo was deemed credible and reliable. They had a clear view of the assailants, aided by the vehicle’s headlights and the breaking dawn, and they personally knew Castillo as a co-resident. The Court emphasized that positive identification, when categorical and consistent, prevails over a denial and alibi, which are inherently weak defenses. Alibi must demonstrate not only that the accused was elsewhere but that it was physically impossible for him to be at the crime scene, a burden Castillo failed to meet.
However, the Court modified the penalties. For the three deaths, the qualifying circumstance of treachery was present as the attack was sudden and rendered the victims helpless. The Court found the crimes to be three separate acts of murder, not a complex crime. Since no aggravating or mitigating circumstances attended the crimes, the proper penalty for each murder was reclusion perpetua. For the injuries to the four surviving victims, the Court found that the prosecution did not prove that the assailants performed all acts of execution to consummate the killing. Thus, the crimes were downgraded from frustrated murder to attempted murder. The Court imposed an indeterminate sentence for each count of attempted murder and ordered civil indemnities.