G.R. No. 207805 . November 22, 2017.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. CESAR BALAO Y LOPEZ, ACCUSED-APPELLANT.

FACTS

Accused-appellant Cesar Balao was charged with the murder of Wilfredo Villaranda on April 10, 1991, in Manila. The prosecution’s case rested primarily on the eyewitness account of Rodel Francisco, who testified that he saw Balao, along with Roberto Espejo and a certain Purong, at the scene. Francisco, standing four to five meters away, stated he saw Balao suddenly appear behind the victim, who was on a bicycle talking to Espejo and Purong, and stab him in the chest with a fan knife. He identified Balao as a known troublemaker in the area. The victim’s brother, Christopher Villaranda, testified about a prior altercation with Espejo, who threatened to report him to Balao, providing a potential motive.
The defense interposed alibi, claiming Balao was in Cagayan Province with his family at the time of the crime. He alleged they had left Manila on April 9, 1991, to visit Piat Church, returning on April 14. This was corroborated by his father and sister, who presented photographs of the trip. The Regional Trial Court convicted Balao of murder, sentencing him to reclusion perpetua. The Court of Appeals affirmed the conviction, prompting this final appeal.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt based on the testimony of a single eyewitness, despite the defense of alibi and the alleged lapse of time affecting the witness’s identification.

RULING

The Supreme Court affirmed the conviction. The Court held that the testimony of a single eyewitness, if credible and positive, is sufficient to produce a conviction beyond reasonable doubt. The Court found the testimony of Rodel Francisco to be clear, credible, and consistent. He had a clear view of the incident from a short distance, knew the accused-appellant by face as a local troublemaker, and provided a straightforward narrative of the sudden and treacherous attack. The lapse of time between the crime in 1991 and his court identification did not, by itself, impair his credibility, as the quality and consistency of his testimony were upheld.
The defense of alibi was correctly rejected. For alibi to prevail, it must be demonstrated that the accused was so far away that it was physically impossible for him to have been at the scene of the crime. The evidence for the alibi, including the presented photographs, was deemed insufficient to prove this impossibility. The defense failed to conclusively establish that Balao was already in Cagayan at the precise time of the stabbing on April 10, 1991. Positive identification, when categorical and consistent, prevails over a weak alibi. The qualifying circumstance of treachery was duly proven, as the attack was sudden and from behind, giving the victim no opportunity to defend himself.