G.R. No. 173282 ; March 4, 2008
JOSE INGAL y SANTOS, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Jose Ingal was charged with murder for the stabbing death of Rolando Domingo on March 2, 1987, in a carinderia in Tondo, Manila. The prosecution’s eyewitnesses, carinderia owner Aida Bona and helper Rosalinda Tan, positively identified Ingal as the sole assailant. They testified that the victim was eating when Ingal suddenly approached, pulled his hair, and stabbed him multiple times before calmly walking away. The medico-legal officer confirmed the victim sustained fatal stab wounds. Ingal was arrested only in August 1994. He interposed the defense of alibi, claiming he was in Cavite at the time of the incident, and denied knowing the eyewitnesses.
The Regional Trial Court convicted Ingal of murder qualified by treachery. The Court of Appeals affirmed the conviction. Ingal appealed to the Supreme Court, arguing the eyewitness identification was unreliable due to the seven-year delay in his arrest and the witnesses’ initial failure to give sworn statements.

ISSUE

The core issue is whether the positive identification of the petitioner by credible eyewitnesses prevails over his defense of alibi and claims of unreliable identification.

RULING

The Supreme Court affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the assessment of witness credibility is best undertaken by the trial judge. The positive, categorical, and consistent testimonies of prosecution witnesses Bona and Tan, who had no ill motive to falsely testify, were given full credence. They provided detailed accounts and even identified a distinguishing mole on Ingal’s eyelid. The delay in arrest and initial reluctance to give sworn statements were satisfactorily explained by the witnesses’ fear and their condition to cooperate only upon the suspect’s apprehension; such delay does not impair their credibility where their identification is convincing.
The defense of alibi was correctly rejected for being inherently weak and unsubstantiated by clear and convincing proof. For alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of being at the crime scene. Ingal failed to do so. The qualifying circumstance of treachery was properly appreciated, as the attack was sudden and unexpected, depriving the unarmed victim of any chance to defend himself. The Court found no reason to deviate from the concurrent conclusions of the lower courts.