G.R. No. 79160. February 23, 1990
THE PEOPLE OF THE PHILIPPINES, Plaintiff-appellee, vs. MARIO BUSTARDE Y PAMA AND ANTONIO MARTIN, JR. Y VLACER, Accused-appellants.

FACTS

Accused-appellants Mario Bustarde and Antonio Martin, Jr. were convicted of murder for the killing of Jaime Habar by the Regional Trial Court of Manila and sentenced to reclusion perpetua. The conviction rested primarily on the eyewitness account of Victoria Lacap, a manicurist. She testified that on August 3, 1983, in Divisoria, Manila, she saw from a distance of three to four meters two persons, identified as Martin and an unknown companion, holding the victim’s hands while Bustarde stabbed him from behind. She identified the appellants at a police line-up the following day. Her testimony was corroborated by the medico-legal findings of Dr. Rodolfo Lisondra, who confirmed the victim sustained three stab wounds in the back, inflicted in rapid succession, consistent with the victim being held and immobilized.
The defense presented an alibi, claiming they were elsewhere during the incident, and sought to discredit Lacap’s testimony. They highlighted alleged inconsistencies, such as her inability to state the exact number of stab wounds and a purported contradiction regarding the timing of her report to the victim’s grandmother versus the grandmother’s own statement about going to the police station. The defense also presented a witness, Doganato, who claimed to have seen the stabbing but testified with an unnaturally detached and indifferent demeanor.

ISSUE

Whether the guilt of the accused-appellants for the crime of murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the alleged flaws in eyewitness Victoria Lacap’s testimony to be either non-existent or exaggerated. Her inability to recall the precise number of stab wounds did not negate her overall credibility, given her state of shock and the clarity of her identification from an unobstructed view at close range. The Court found no material contradiction between her account and that of the victim’s grandmother. The testimony was deemed credible, especially as she had no motive to falsely accuse the appellants.
The Court upheld the trial court’s assessment of the defense’s alibi as weak and unpersuasive. It specifically noted the incredibility of defense witness Doganato, whose bizarrely indifferent demeanor while describing a violent killing rendered his narrative unreliable. The evidence established conspiracy, as the acts of the two accused holding the victim while the third stabbed him demonstrated concerted action. The manner of attack—suddenly stabbing the immobilized victim from behind—constituted treachery (alevosia), qualifying the killing as murder. The Supreme Court thus found no reason to overturn the factual findings and legal conclusions of the trial court.