G.R. No. 172184; July 10, 2007
NESTOR B. DECASA, Petitioner, vs. THE HONORABLE COURT OF APPEALS and THE PEOPLE OF THE PHILIPPINES, Respondents.

FACTS

Petitioner Nestor Decasa was charged with homicide for the killing of Teodoro Luzano on August 29, 1992, in Bilar, Bohol. The prosecution’s case primarily rested on the eyewitness account of Rogelio Boco, who testified that around 8:00 PM, under a bright moon, he saw Decasa and Luzano arguing about irrigation water. From a distance of about five meters, Boco claimed he saw Decasa hack Luzano on the neck and forehead with a bladed weapon, causing Luzano to fall. The victim’s body was discovered the next morning, and a post-mortem examination confirmed the cause of death as hemorrhage from multiple sharp-force wounds.
Decasa presented an alibi, denying any involvement. He testified that on the evening in question, he was at home with his family from supper time until dawn the next day, praying and sleeping, and did not go out. He asserted he had no quarrel with Luzano as their rice fields used different water sources. He also challenged the credibility of Boco’s testimony by presenting a calendar to show the moon was not full on that night, implying poor visibility.

ISSUE

The core issue is whether the prosecution proved Decasa’s guilt for the crime of homicide beyond reasonable doubt, specifically concerning the credibility of the lone eyewitness account versus the defense of alibi.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court upheld the factual findings of the lower courts, giving great weight to the assessment of witness credibility. The Court found no reason to deviate from the trial court’s conclusion that Rogelio Boco was a credible witness. His testimony was clear, straightforward, and consistent on material points. He had no ill motive to falsely testify against the accused. The defense’s attempt to impeach his testimony by questioning lunar illumination was insufficient to cast doubt, as Boco positively identified Decasa from a short distance during the altercation.
The defense of alibi was rightly rejected. Jurisprudence consistently holds that alibi is a weak defense and cannot prevail over the positive identification of the accused by a credible witness. For alibi to prosper, the accused must prove 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. Decasa failed to establish this impossibility, as his claimed location was merely 100 meters from his in-laws’ house, a distance he could have traversed. The positive identification thus prevails. The Court found the totality of evidence sufficient to establish moral certainty of Decasa’s guilt for homicide.