G.R. No. 78899 March 22, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MELCHOR BESA, accused-appellant.

FACTS

On the evening of May 19, 1980, in Jamindan, Capiz, the victim Gaspar Besa, his brother accused-appellant Melchor Besa, and two others were drinking beer outside a store. The group was merrymaking as it was the eve of the barangay fiesta and Gaspar had recently returned after six years in Mindanao. An hour into their session, Melchor suddenly stood up, went behind his seated brother, and stabbed him once in the back with a knife approximately ten inches long. Gaspar, before expiring, identified his assailant as “Nong Melchor.” The wound, as per the medical certificate, was caused by a sharp instrument entering the left paravertebral line, reaching the lungs, and causing immediate death from internal hemorrhage and cardiac arrest.

ISSUE

The core issue is whether the prosecution evidence, particularly the eyewitness testimonies, sufficiently established the identity of Melchor Besa as the perpetrator of the killing beyond reasonable doubt, despite the defense of alibi and the claim of a lack of motive.

RULING

The Supreme Court affirmed the conviction for murder. The legal logic centers on the strength of positive identification overriding the weak defense of alibi. Three prosecution eyewitnesses—Mariano Luces, Thelma Belleza, and Santiago Villanueva—who were present at the scene, consistently and categorically testified that they saw accused-appellant stab the victim from behind. Their testimonies were found credible by the trial court, which observed their demeanor, and were corroborated by the medical findings on the location and nature of the fatal wound. The Court emphasized the well-established doctrine that alibi is inherently weak and cannot prevail over the positive identification of the accused by credible witnesses who had no ill motive to testify falsely. The claim of lack of motive was deemed irrelevant in this context. The Court ruled that motive becomes significant only when the identity of the assailant is in doubt or the evidence is purely circumstantial, which was not the case here. The manner of attack—a sudden stabbing from behind on an unarmed and unsuspecting victim who was seated—conclusively established the qualifying circumstance of treachery (alevosia), thus properly qualifying the killing as murder. The penalty of reclusion perpetua and the award of indemnity were sustained.