G.R. No. 177571 ; September 29, 2008
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. DEAN MARTIN y SARVIDA @ DENDEN and ROMEO TANOAN y MACAILIG, Accused-Appellants.

FACTS

On the evening of April 2, 1995, Rogelio Dihan was driving his passenger jeepney with his wife Dolores and their children in San Andres Bukid, Manila. While stopped at a red light, accused-appellant Romeo Tanoan suddenly approached Rogelio from behind and stabbed him multiple times. Dolores and the children pleaded in vain for Tanoan to stop. When Dolores attempted to alight to seek help, accused-appellant Dean Martin, along with two other unidentified males, blocked her path and prevented her from exiting. The assailants then fled towards Perlita Street. Rogelio managed to drive a short distance before collapsing. He was rushed to the hospital but was pronounced dead on arrival. The incident was also witnessed by Sergio Delos Santos, a fellow jeepney driver who was directly behind Rogelio’s vehicle. Sergio saw Tanoan pass in front of his jeepney, approach Rogelio, and stab him, and also witnessed Martin push Dolores back inside the vehicle when she tried to get out.
Two months later, on June 5, 1995, Dolores chanced upon Tanoan bathing near the crime scene. She reported this to authorities, leading to Tanoan’s arrest. At the police station, Dolores, Sergio, and another witness identified Tanoan as the assailant. Tanoan subsequently gave a statement implicating Martin as his co-conspirator, leading to Martin’s arrest. The following day, Sergio identified Martin as the person who hindered Dolores. The accused were charged with Murder. At trial, they interposed the defenses of denial and alibi. Martin claimed he was sewing in his shanty 50 meters away during the incident, while defense witnesses presented Tanoan as merely a bystander after the fact.

ISSUE

1. Whether the prosecution witnesses positively and credibly identified accused-appellants as the perpetrators of the crime.
2. Whether the defenses of denial and alibi should prevail over the positive identification by the prosecution witnesses.
3. Whether the qualifying circumstance of treachery (alevosia) was sufficiently proven to convict the accused of Murder.

RULING

The Supreme Court AFFIRMED the conviction of accused-appellants for Murder, with modifications to the awarded damages. The Court upheld the findings of the trial court and the Court of Appeals.
1. On Positive Identification: The Court found the testimonies of prosecution witnesses Dolores Dihan and Sergio Delos Santos to be clear, consistent, and credible. As the victim’s wife, Dolores had no motive to falsely accuse innocent persons and her natural interest was to see the true culprits punished. Her opportunity to observe the assailants was ample as the attack occurred at close range inside the jeepney. Sergio’s corroborative testimony, given from his vantage point in the adjacent vehicle, was likewise credible and reinforced the prosecution’s narrative. The subsequent identifications at the police station were merely confirmatory. The Court emphasized that positive identification, when categorical and consistent, prevails over denial and alibi.
2. On Denial and Alibi: The defenses of denial and alibi were correctly rejected. For alibi to prosper, the accused must prove not only that they were elsewhere when the crime occurred but that it was physically impossible for them to have been at the scene. Both accused-appellants failed to meet this burden. Martin’s claimed location was a mere 50 meters away, and defense evidence placed Tanoan near the scene shortly after the incident. The Court reiterated the doctrine that alibi is inherently weak and cannot stand against positive identification.
3. On the Qualifying Circumstance of Treachery: The Court affirmed the presence of treachery (alevosia). The attack was sudden and unexpected, executed in a manner that rendered the victim, who was defenselessly driving and seated, unable to offer any resistance or defense. Tanoan approached from behind and immediately launched a lethal assault with a bladed weapon. This method of attack, which ensured the execution of the crime without risk to the assailant arising from any defense the victim might make, squarely qualifies the killing as Murder.
4. On Damages: The Court modified the awards in line with prevailing jurisprudence. It sustained the award of PhP 50,000 as civil indemnity and PhP 50,000 as moral damages. However, it clarified that since the proven actual expenses were only PhP 10,000, the award of PhP 25,000 as temperate damages was proper. Exemplary damages in the amount of PhP 25,000 were also awarded due to the presence of the qualifying aggravating circumstance of treachery.

DOCTRINES

1. Positive Identification vs. Denial and Alibi: Positive, categorical, and consistent identification by credible witnesses prevails over the defenses of denial and alibi, which are inherently weak. For alibi to succeed, the accused must demonstrate not only their presence elsewhere but the physical impossibility of their presence at the locus criminis.
2. Treachery (Alevosia): Treachery is present when the offender employs means, methods, or forms in the execution of the crime which tend directly and specially to ensure its execution, without risk to himself arising from the defense which the offended party might make. A sudden and unexpected attack on an unarmed and unsuspecting victim from behind qualifies as treacherous.
3. Credibility of Witnesses: The testimony of a witness who is a relative of the victim is not automatically suspect. Such testimony is entitled to full weight and credit, especially when no ill motive is shown, as the witness’s natural interest is to secure the conviction of the true culprit.
4. Award of Damages in Murder Cases: In convictions for Murder, the following damages are typically awarded: (a) PhP 50,000 as civil indemnity ex delicto; (b) PhP 50,000 as moral damages; (c) PhP 25,000 as temperate damages when actual damages proven are less than this amount; and (d) PhP 25,000 as exemplary damages when a qualifying aggravating circumstance like treachery is present.