GR 82696; (September, 1989) (Digest)
G.R. No. 82696 September 8, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NOELITO MANZANARES, accused-appellant.
FACTS
The appellant, Noelito Manzanares, was charged with murder for the stabbing death of Rolando Frias on January 3, 1985, in Valenzuela, Metro Manila. The information alleged conspiracy with two others, employing treachery and abuse of superior strength. Only the appellant was apprehended. The prosecution presented two eyewitnesses: the victim’s wife, Lydia Frias, and Vilma Bonacwa. Lydia testified that she and her husband were waiting for a jeepney when the appellant suddenly stabbed him, after which two companions joined in the attack. Vilma Bonacwa corroborated seeing the appellant and another chase and stab the victim. The defense was alibi, claiming the appellant was asleep at home. The appellant also alleged that Lydia Frias testified falsely due to a prior grudge stemming from a fistfight between their families and that Vilma Bonacwa was biased due to a past argument.
ISSUE
Whether the trial court erred in convicting the appellant of murder based on the testimonies of the prosecution witnesses and in rejecting the defense of alibi and claims of witness bias.
RULING
The Supreme Court affirmed the conviction. The legal logic centered on the credibility of the prosecution witnesses and the weakness of the defense. The Court found the testimonies of Lydia Frias and Vilma Bonacwa credible and consistent. Their positive identification of the appellant, a neighbor known to them, was deemed reliable, especially given the well-lit scene from store lights and a streetlamp. The alleged motives for false testimony—a family grudge and a past argument—were insufficient to overcome the positive identification, particularly considering the close cultural relationship of being “compadres.” The defense of alibi, inherently weak, could not prevail over positive identification. The Court also noted the appellant’s flight, as evidenced by an unserved subpoena and a five-month delay in his apprehension, indicating consciousness of guilt. The crime was properly qualified as murder by treachery, as the attack was sudden and employed bladed weapons against an unarmed and unsuspecting victim, ensuring execution without risk to the assailants. The circumstance of abuse of superior strength was absorbed by treachery. The penalty of reclusion perpetua and the awarded damages were sustained.