G.R. No. L-340298 March 30, 1971
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. IGNACIO MERCADO, defendant-appellant.

FACTS

The defendant-appellant, Ignacio Mercado, together with Nemesio Bulahan (at large), was charged with the murder of Escolastica Amparo on May 26, 1965, in Dolores, Quezon. The prosecution’s main witness was Jose Pamarez, a herb healer. He testified that around 11:00 p.m. on said date, while walking in Barrio Bulakin, he heard calls for help. Using his flashlight, he saw Mercado and Bulahan embracing the victim. He observed Mercado holding a sharp-bladed weapon and the victim’s breast bleeding. When Pamarez yelled at them, Bulahan told Mercado to chase him, causing Pamarez to flee. The victim’s body, discovered the next morning, bore multiple stab and incised wounds, indicating a struggle. The defense consisted solely of Mercado’s alibi that he was at home with his family the entire evening.

ISSUE

The core issue is whether the trial court erred in convicting Mercado based primarily on the testimony of Jose Pamarez, despite the defense of alibi and alleged inconsistencies in the witness’s account.

RULING

The Supreme Court affirmed the conviction. The legal logic rests on the established principle that the assessment of witness credibility by the trial court is accorded high respect, as it is in the best position to observe demeanor. The Court found no compelling reason to overturn the trial judge’s finding that Pamarez was credible. His positive identification of Mercado at the crime scene, with sufficient illumination from his flashlight, was clear and categorical. The delay in reporting the incident was sufficiently explained by his fear, which did not impair his credibility. Conversely, Mercado’s defense of alibi was inherently weak. For alibi to prosper, it must be shown that the accused was so far away that he could not have been physically present at the locus criminis. Mercado’s own admission placed his house a mere 200 meters from the crime scene, making it easily possible for him to have committed the crime and returned home. His failure to impute any ill motive to Pamarez for testifying against him further weakened his defense. The crime was properly qualified as murder due to the abuse of superior strength. The Court modified the civil indemnity, increasing it from P6,000 to P12,000, but affirmed the penalty of life imprisonment.