GR 32864; (March, 1989) (Digest)
G.R. No. 32864 March 8, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. JOSE CASTILLO Y RIZADO, accused-appellant.
FACTS
On May 8, 1970, in Manila, Dalmacio Roxas was shot and killed. The prosecution presented two eyewitnesses, Restituto Luna and Luciano de Guzman. Luna, the victim’s brother-in-law, testified that while walking home with Roxas, they encountered a group of five men, including appellant Jose Castillo and co-accused Emmanuel Maliclic. Luna stated that Castillo, armed with a short gun, confronted the victim and, while positioned behind him, fired multiple shots. He heard Maliclic say, “he is already dead, let us run,” after the shooting. De Guzman, an unrelated bystander, corroborated the account, identifying Castillo as the shooter and Maliclic as present in the armed group. Both witnesses attested to sufficient illumination from a Meralco lamp post.
The defense consisted of alibi. Castillo claimed he was at a different location, attending a birthday party, and presented corroborating witnesses. The trial court convicted Castillo as principal and Maliclic as accomplice to murder qualified by treachery, sentencing Castillo to life imprisonment and ordering indemnity of P12,000.00 to the heirs. Castillo appealed, challenging witness credibility and the rejection of his alibi.
ISSUE
Whether the trial court erred in convicting the appellant based on the testimonies of the prosecution witnesses and in rejecting the defense of alibi.
RULING
The Supreme Court affirmed the conviction with modification on the civil indemnity. The Court upheld the trial court’s assessment of witness credibility, emphasizing that the trial judge’s firsthand observation of witness demeanor is accorded great respect. The positive identification by two eyewitnesses, who were consistent on material points and had no ill motive to testify falsely, prevailed over the appellant’s alibi. The Court found the alibi weak, noting it was not physically impossible for the appellant to have been at the crime scene, which was near his house. The qualifying circumstance of treachery was correctly appreciated, as the attack from behind without warning rendered the victim defenseless. The penalty of reclusion perpetua (life imprisonment) was affirmed. However, following prevailing jurisprudence, the civil indemnity was increased from P12,000.00 to P30,000.00. The decision of the lower court was thus AFFIRMED with the stated modification.