G.R. No. L-27606 July 30, 1976
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOMICIANO BERAME alias DOMING, defendant-appellant.

FACTS

The appellant, Domiciano Berame, was convicted of murder for the killing of Quirico Maningo on the evening of April 13, 1966, in Danao City. The prosecution’s case rested on direct and circumstantial evidence. Danilo Maningo, the victim’s adopted son who was seated a meter away, positively identified Berame as the assailant who fired several shots at the victim from the main door of their house, which was illuminated by a “big light.” After the shooting, Danilo saw Berame and another person flee. Corroborative testimonies placed two individuals running from the scene, with one matching Berame’s description.
Further circumstantial evidence solidified the prosecution’s case. A rubber shoe recovered from a nearby swampy area, where the assailants were suspected to have hidden, perfectly fit Berame’s right foot. Additionally, Berame fled after the incident and surrendered only a month later. The dying declaration of his co-accused, Anastacio Montinola, who was mortally wounded in a shootout with police, also implicated Berame as a participant in the killing. The defense relied solely on an alibi, claiming Berame was in Cebu City, approximately 32 kilometers away, at the time of the crime.

ISSUE

The core issue is whether the trial court erred in convicting the appellant based on the evidence presented, thereby rejecting his defense of alibi.

RULING

The Supreme Court affirmed the conviction. The legal logic centers on the strength of the prosecution’s evidence against the inherent weakness of the defense of alibi. Positive identification by a credible eyewitness, Danilo Maningo, who had an unobstructed view under sufficient lighting and was in close proximity, prevails over an unsubstantiated alibi. The Court emphasized that alibi is inherently unreliable and easily fabricated, and it cannot stand against positive identification unless the accused demonstrates the physical impossibility of being at the crime scene.
The circumstantial evidence formed a cohesive chain leading to a fair and reasonable conclusion of guilt. The recovery of the rubber shoe fitting the appellant, his flight and delayed surrender (indicative of a guilty conscience), and the dying declaration of his co-accused all corroborated the direct testimony. The Court found the collective weight of this evidence to be conclusive. The defense failed to provide a credible explanation for these corroborating circumstances or to successfully impeach the eyewitness’s testimony. Consequently, the trial court’s assessment of the evidence was correct, and the conviction for murder was upheld, as the prosecution successfully proved the appellant’s guilt beyond a reasonable doubt.