G.R. No. L-28506. January 31, 1977.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANATALIO LINGAO and MAURO MANCERA, defendants-appellants.

FACTS

Appellants Anatalio Lingao and Mauro Mancera, union officials during a strike at the Filipino Pipe and Foundry Corporation, were convicted of murder for the death of Jose Bello, a “scab” or strike-breaker. In the early morning of September 24, 1964, Bello and fellow workers, after being stoned by strikers, fled and encountered a jeep at a street intersection. Prosecution witnesses Ernesto Poloyapoy and Felipe Soriano testified that under a mercury lamp, they clearly saw appellants alight from the jeep with armed companions. Bello, left behind, was grabbed and forcibly dragged by appellants towards a dark area. This was the last time he was seen alive; his body was found floating in the nearby Pasig River the next day. The autopsy concluded death was due to asphyxia by submersion.
The appellants denied involvement, interposing alibi. Mancera claimed he was leading the picket line, while Lingao asserted he was at home and later arranging bail for detained strikers. They assailed the credibility of prosecution witnesses and argued the circumstantial evidence was insufficient for conviction.

ISSUE

Whether the circumstantial evidence presented by the prosecution is sufficient to prove the guilt of the appellants beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction, holding that the totality of the circumstantial evidence constituted an unbroken chain leading to the reasonable and moral certainty of the appellants’ guilt. The Court meticulously analyzed the established circumstances: (1) the appellants, as strike leaders, had a clear motive against the deceased, a strike-breaker, with Lingao having previously issued threats; (2) credible eyewitnesses positively identified appellants as among those who alighted from the jeep and grabbed the victim; (3) this forcible seizure occurred moments before Bello’s disappearance and very near the location where his body was later recovered; and (4) no other persons were shown to have any motive to harm the victim. These facts, taken together, exclude every reasonable hypothesis of innocence.
The Court rejected the defense of alibi for lack of physical impossibility, noting the proximity of the appellants’ claimed locations to the crime scene. The alleged inconsistencies in the witnesses’ testimonies were deemed trivial and not related to vital points of the case. The penalty of reclusion perpetua was sustained. However, the Court modified the judgment regarding preventive imprisonment credit for appellant Mancera, ruling he should be credited with the full time if he agreed in writing to follow prison rules, otherwise four-fifths, pursuant to the Revised Penal Code. The decision of the trial court was affirmed with this modification.