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, who remained at large. The prosecution presented two eyewitnesses. Lydia Frias, the victim’s wife, testified she and her husband were waiting for a jeepney when the appellant suddenly approached and stabbed him, after which two companions joined in the attack. Vilma Bonacwa, a disinterested witness, corroborated seeing the appellant and another chase and stab the victim. The autopsy revealed seven stab wounds, two of which were fatal.
The appellant denied involvement, interposing an alibi that he was asleep at home at the time. He claimed Lydia Frias testified falsely due to a prior grudge stemming from a fistfight between their families, and that she had pressured him to falsely accuse another. He similarly alleged bias from Bonacwa over a past romantic dispute. The trial court convicted him of murder and sentenced him to reclusion perpetua, prompting this appeal challenging witness credibility and sufficiency of evidence.

ISSUE

Whether the prosecution evidence, primarily the testimonies of the two eyewitnesses, is sufficient to prove the guilt of the appellant for murder beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction, finding the prosecution evidence sufficient. The Court upheld the credibility of the eyewitnesses, Lydia Frias and Vilma Bonacwa. It rejected the appellant’s claim of fabricated testimony due to grudge, noting that Lydia Frias was the appellant’s neighbor and the godmother of his child—relationships that in Philippine culture make it highly improbable she would falsely implicate him in her husband’s murder. Her testimony was strongly corroborated by Bonacwa, a disinterested witness. Both witnesses positively identified the appellant, a neighbor known to them, under well-lighted conditions from store lights and a nearby streetlamp.
The legal logic centers on the well-settled rule that positive identification by credible witnesses prevails over alibi and denial. The Court found the appellant’s alibi weak for failing to prove the physical impossibility of his presence at the crime scene. Furthermore, the circumstance of flight—his evasion of arrest for five months—was deemed indicative of consciousness of guilt. The crime was properly qualified as murder by treachery. The attack was sudden, executed by multiple armed assailants against an unarmed and unsuspecting victim, ensuring its execution without risk to the attackers. The aggravating circumstance of abuse of superior strength was absorbed by treachery. The penalty of reclusion perpetua was affirmed as correct under the applicable law.