G.R. No. L-31570. August 30, 1971.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GAVINO CUATON, defendant-appellant.

FACTS

In the evening of December 24, 1967, in Nasugbu, Batangas, Vicente Tandog was asleep inside a room in his house. His wife, Francisca Ilao, was cooking dinner. At about 8:00 PM, as Francisca entered the room to wake her husband, she saw a man fire a shot through the window at Vicente. Their nephew, Romeo Salanguit, who was lying awake in the house, also witnessed the shooting. The assailant fled, using a short ladder found later under the window. Francisca rushed to her husband, who was bleeding from the mouth and nose, and shouted for help. Police were summoned, and Francisca immediately identified the assailant as their neighbor, Gavino Cuaton. Vicente died shortly thereafter from a fatal gunshot wound to the neck.
The prosecution presented the eyewitness accounts of Francisca and Romeo, who positively identified Cuaton as the shooter. Their house was illuminated by a petromax lamp at the time. The defense presented an alibi, claiming Cuaton was at his own house, about 100 meters away, cooking with his wife. Cuaton asserted his wife left to investigate a commotion and later returned with news of the shooting, while he stayed behind to mind their cooking. He did not visit the scene until the next day and did not attend the funeral.

ISSUE

Whether the trial court erred in convicting Gavino Cuaton of murder based on the credibility of the prosecution witnesses and in rejecting his defense of alibi.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the strength of positive identification over a weak alibi. The Court found the testimonies of Francisca Ilao and Romeo Salanguit credible and reliable. Minor inconsistencies regarding the exact time of Vicente’s death were deemed inconsequential and understandable given the traumatic event. The trial judge, who observed the witnesses firsthand, gave full credence to their accounts, and no evidence indicated this evaluation was erroneous. The witnesses had a clear opportunity to recognize Cuaton: the house was well-lit, Cuaton was a known neighbor, and both witnesses had direct lines of sight during the shooting.
Cuaton’s alibi was correctly rejected. For an alibi to prevail, it must be physically impossible for the accused to be at the crime scene. Here, it was not impossible, as Cuaton’s house was merely 100 meters away, allowing him easy access to and from the scene. The Court found his alibi narrative inherently suspect—it was unusual for his wife to investigate the commotion while he stayed behind to cook, and his delayed visit to the victim’s house and absence from the funeral raised further suspicion. Moreover, the paraffin test conducted by the NBI forensic chemist, which found gunpowder nitrates on Cuaton’s hands, provided strong unbiased corroboration to the eyewitness identification. Thus, the positive identification, corroborated by physical evidence, conclusively established guilt beyond reasonable doubt, rendering the alibi untenable.