G.R. No. 78730 March 8, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SALVADOR LACAP alias “BADOR”, WILLIAM ISIP alias “TURO”, ANGELITO YABUT alias “ITUK”, EDUARDO YABUT alias “EDDIE”, and REYNALDO IGNACIO alias “PAKANG”, defendants-appellants.

FACTS

On January 22, 1986, elderly sisters Filomena and Eduviges Mallari were found dead with multiple stab wounds in their house in Masantol, Pampanga. Cash and jewelry were stolen. Appellants Salvador Lacap, William Isip, Angelito Yabut, Eduardo Yabut, and Reynaldo Ignacio were charged with Robbery with Double Homicide. Upon arrest, Ignacio and Angelito Yabut executed extra-judicial confessions implicating themselves and their co-accused, with Ignacio identifying Lacap as the mastermind. At arraignment, Ignacio pleaded guilty, while the four other appellants pleaded not guilty.
During trial, Ignacio recanted his confession and testified that he alone committed the robbery and killings, claiming he acted out of panic when discovered. He asserted his co-accused were not present. The other appellants presented alibis, claiming they were drinking elsewhere and then went home to sleep. The prosecution presented eyewitness Abelardo Mallari, who testified he saw all five appellants inside the victims’ house around the time of the crime.

ISSUE

Whether the guilt of appellants Salvador Lacap, William Isip, Angelito Yabut, and Eduardo Yabut was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The trial court correctly rejected Ignacio’s claim of sole responsibility and the appellants’ alibis. The legal logic rests on the weakness of the defense evidence against the strength of the prosecution’s proof. First, Ignacio’s judicial confession, given during his plea, was a judicial admission binding upon him. His subsequent retraction during trial, intended to exculpate his co-accused, was inherently unreliable and could not prevail over his prior solemn declaration and the positive identification by an eyewitness. The Court emphasized that retractions are viewed with disfavor and are insufficient grounds for acquittal.
Second, the appellants’ alibis were inherently weak and could not overcome the positive identification by eyewitness Abelardo Mallari. For an alibi to prosper, it must be shown that the accused was so far away that it was physically impossible for them to be at the crime scene. The appellants failed to prove this physical impossibility, as the distance between their claimed location and the victims’ house was not insurmountable. Positive identification, when categorical and consistent, prevails over alibi.
Finally, the physical evidence conclusively refuted Ignacio’s claim of acting alone. The autopsy revealed the two elderly victims sustained a total of twenty stab wounds (seven and thirteen, respectively), along with other injuries indicative of a struggle against multiple attackers. This medical finding was fundamentally inconsistent with the testimony of a single assailant acting in a sudden panic. The number, nature, and location of the wounds objectively demonstrated a concerted attack by several persons, corroborating the prosecution’s theory of conspiracy among all five accused. Thus, the collective evidence established their guilt beyond reasonable doubt.