G.R. No. 83903 , August 30, 1990
The People of the Philippines, plaintiff-appellee, vs. Octavio Juanga, defendant-appellant.

FACTS

The prosecution’s evidence established that on March 5, 1982, in Leganes, Iloilo, the victim Mamerto Peñaflor Jr. and a companion, Esperidion Dapitas Jr., were drinking. The appellant, Octavio Juanga, arrived and twice declined Peñaflor’s invitations to drink, brushing off the victim’s attempts at reconciliation regarding a prior fistfight. Later, at a house they visited, Juanga appeared twice more before Peñaflor went outside to urinate. Dapitas followed and witnessed Juanga, from behind, point an object at the urinating victim, whisper something, and then fire a shot. Peñaflor was hit and died from multiple pellet wounds. Dapitas and another witness, Thelma Dapitas, positively identified Juanga as the assailant.
The defense presented an alibi. Juanga claimed he was at the farm until 5:00 p.m. and then at the house of ex-Mayor Esperidion Jagunap from 7:30 p.m. to 9:00 p.m., watching television, which was corroborated by the ex-mayor and another witness. He asserted he only learned of the shooting the next day and later went to Manila for work. The trial court convicted Juanga of murder qualified by treachery and sentenced him to reclusion perpetua.

ISSUE

The core issue is whether the trial court erred in convicting the appellant based on the credibility of the prosecution witnesses and in rejecting his defense of alibi.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, finding the testimonies of prosecution witnesses Esperidion Dapitas Jr. and Thelma Dapitas to be clear, positive, and consistent on material points. The alleged inconsistencies in their testimonies were minor and did not detract from their overall reliability. Their positive identification of Juanga as the shooter was categorical.
The defense of alibi was correctly rejected. For alibi to prosper, the accused must demonstrate not only his presence elsewhere but the physical impossibility of his being at the crime scene. The Court noted that the house of ex-Mayor Jagunap, where Juanga claimed to be, was merely 400 meters from the crime scene, negating any physical impossibility. Alibi is inherently weak and cannot prevail over the positive identification by credible witnesses. The Court also found motive in the prior altercation where Juanga was bested, explaining his rejection of the victim’s peace overtures. The attack was sudden, from behind, while the victim was urinating and unable to defend himself, properly qualifying the killing as murder with treachery.