G.R. No. 76048 May 29, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BONIFACIO PIGON, accused-appellant.

FACTS

The accused-appellant, Bonifacio Pigon, was convicted by the Regional Trial Court of robbery with homicide for the killing of Leonito Samson on December 29, 1983, in Galutan, Cataingan, Masbate. The prosecution’s case rested primarily on the eyewitness account of Jaime Deogrades, then 14 years old. Deogrades testified that he, Pigon, and the victim were walking single file to Pigon’s house for a barter transaction involving a goat. During the journey, Pigon suddenly grabbed Samson from behind and, as Samson turned, stabbed him in the chest with a “flamingo” knife. Pigon then robbed the victim of his personal belongings and money, fled with Deogrades, and subsequently detained the witness for several days, threatening him to keep silent.
The defense presented an alibi. Pigon, corroborated by witness Pedro Yanson, claimed he was in San Rafael, Cataingan, from the afternoon of December 28 until 3:00 p.m. on December 29, assisting in preparations for a birthday party at Yanson’s house, located approximately 15 kilometers from the crime scene. The defense asserted it was physically impossible for Pigon to have committed the crime.

ISSUE

The core issue is whether the trial court erred in convicting Pigon based on the testimony of Jaime Deogrades and in rejecting the defense of alibi, thereby finding guilt for robbery with homicide proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of Deogrades’ credibility, finding his testimony clear, straightforward, and consistent. As an eyewitness, his detailed account of the stabbing and subsequent robbery was accorded full weight. The Court emphasized that the testimony of a single credible witness is sufficient for a conviction if it meets the test of reasonable doubt. Minor inconsistencies, such as the witness’s position relative to the victim during the attack, were deemed inconsequential to the core narrative of the crime.
The defense of alibi was correctly rejected. For alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of being at the crime scene at the time of its commission. The Court agreed with the trial court’s finding that the distance between San Rafael and Galutan within the same municipality did not constitute such an impossibility, especially as the areas were accessible by motorized vehicles. Furthermore, the witness Yanson could not have maintained constant surveillance over Pigon during the busy party preparations. Critically, alibi cannot prevail against the positive identification of the accused by a credible eyewitness. The Court found Deogrades’ positive identification of Pigon as the perpetrator to be categorical and unwavering. Consequently, the elements of robbery with homicide were established beyond reasonable doubt, warranting the affirmation of the penalty of reclusion perpetua and the awarded indemnity.