G.R. No. 143126; July 31, 2003
PEOPLE OF THE PHILIPPINES, Appellee, vs. ERIC BALTAZAR Y VILLARUEL, Appellant.

FACTS

The prosecution’s case established that on October 14, 1998, in Pasay City, appellant Eric Baltazar suddenly and repeatedly stabbed Roberto Alba while the latter was seated on a bench conversing with his live-in partner, Rosita La Torre. The attack was so unexpected that the victim could not mount any defense. After the initial assault, Baltazar pursued the fleeing victim until La Torre’s shouts caused him to flee. Roberto Alba later died from multiple stab wounds, including two fatal wounds to the chest. Rosita La Torre positively identified Baltazar in court as the assailant, whom she knew by the alias “Toto Tattoo.” The medical findings confirmed the frontal nature of the wounds inflicted with a sharp instrument.
In his defense, appellant Baltazar interposed alibi and denial. He claimed he was selling cigarettes at Monumento Circle in Caloocan City at the time of the incident. He alleged that his arrest was a result of extortion, as police officers and La Torre demanded money from him, and that he was mauled and forcedly identified. He denied knowing the victim or frequenting the crime scene, and asserted his nickname was “Totoy,” not “Toto Tattoo.”

ISSUE

Whether the prosecution proved the guilt of appellant Eric Baltazar for the crime of Murder beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the positive identification by eyewitness Rosita La Torre to be credible, categorical, and consistent. Her testimony was corroborated by the medical evidence on the number, location, and nature of the wounds. The Court emphasized that alibi is inherently weak and cannot prevail over the positive identification of a credible witness who had no ill motive to falsely testify. For alibi to prosper, the accused must demonstrate not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to have been at the crime scene. Baltazar failed to prove this physical impossibility, as Caloocan City and Pasay City are not so distant as to preclude travel between them. His claim of frame-up and extortion was unsupported by clear and convincing evidence. The qualifying circumstance of treachery was duly established, as the attack was sudden and deliberate, employing a method that ensured the execution of the crime without risk to the assailant from any defense the victim might make. The Court thus upheld the finding of guilt for Murder, sentencing Baltazar to reclusion perpetua and modifying the award of damages.