G.R. No. L-32754-5 July 21, 1978
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MANUEL PILONES y IBAÑEZ, defendant-appellant.

FACTS

In the early morning of April 10, 1970, a wake was being held at a house on F. Posadas Street in Punta, Sta. Ana, Manila. The house was stoned, prompting attendees, including Nicanor Ilagan and Antonio Renolia, to go outside. Ilagan was shot in the knee and fell. As Renolia attempted to assist him, Renolia was also shot by the same assailant, resulting in his death. Ilagan saw the assailant’s face under a streetlight and later identified him as someone he had seen challenging people to a fight a week prior.
The police investigation initially stalled. On May 30, 1970, Manuel Pilones was arrested for vagrancy. Ilagan, brought to the police precinct, positively identified Pilones at close range as the shooter. Pilones remained silent during this confrontation. At trial, Pilones presented an alibi, claiming he was in Olongapo City from December 31, 1969, to May 28, 1970. His corroborating witness gave contradictory testimony regarding the date of his departure. Pilones also claimed he was framed by a patrolman due to a prior grudge.

ISSUE

The primary issue is whether the prosecution evidence, particularly the eyewitness identification by Ilagan, is sufficient to establish the guilt of Manuel Pilones for murder and frustrated murder beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the classification of the crime against Ilagan. The Court found Ilagan’s identification of Pilones as the assailant to be credible and reliable. Ilagan had a clear view of the shooter under adequate lighting, remembered him from a prior encounter, and made a positive identification without hesitation during a police confrontation where Pilones notably offered no denial. The defense of alibi was correctly rejected for being weak and uncorroborated by credible witnesses, especially in light of the positive identification.
The Court also addressed ancillary arguments. The difference between the metallic fragment from Ilagan’s wound and the slug from Renolia’s body did not create reasonable doubt, as it did not preclude the possibility of a single assailant using different weapons. A motion for new trial based on a new witness affidavit was properly denied, as the affidavit referred to a different “riot” and the information could have been discovered earlier. The Court found no ill motive for Ilagan to falsely accuse Pilones.
However, the Court modified the judgment regarding the crime against Ilagan. Since the knee wound was not fatal and the acts of execution were not complete, the crime constituted attempted murder, not frustrated murder. Pilones was thus sentenced for murder (reclusion perpetua) and attempted murder (an indeterminate penalty). The indemnity to Renolia’s heirs was affirmed, and an indemnity was additionally awarded to Ilagan.