G.R. No. 91492 January 19, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VALENTINO GAMIAO y DE JESUS and ROLANDO CAOILE y BAUTISTA, accused. ROLANDO CAOILE y BAUTISTA, accused-appellant.

FACTS

Accused Rolando Caoile and Valentino Gamiao were charged with Murder for the stabbing death of Eulogio Armas. The prosecution evidence established that on August 17, 1982, a group including the victim was confronted by eight members of the Samahang Ilokano fraternity, including Caoile and Gamiao. After a brief exchange, the fraternity members drew concealed knives. Caoile initially attempted to stab another individual, Wilfredo Quiambao, who managed to escape. Gamiao then stabbed Armas, who was restrained by others. Caoile subsequently stabbed the fallen victim, and the group took turns attacking him before fleeing. Armas sustained six stab wounds and died. Prosecution witnesses Baarde and Quiambao positively identified Caoile in a police line-up and later pointed out Gamiao near their school, leading to his arrest.
The defense relied on alibi. Appellant Caoile claimed he was working in Dinalupihan, Bataan, on the date of the incident, loading cartons from past 2:00 PM until about 8:00 PM. He asserted he was arrested in Quezon City months later, in October 1982. The trial court convicted both accused of Murder qualified by treachery and sentenced them to reclusion perpetua. Only Caoile appealed, arguing the trial court erred in rejecting his alibi and in convicting him despite an incomplete transcript of stenographic notes.

ISSUE

The core issue is whether the defense of alibi and the claim regarding missing transcripts warrant the reversal of appellant Caoile’s conviction for Murder.

RULING

The Supreme Court affirmed the conviction. On the defense of alibi, the Court upheld the trial court’s assessment of witness credibility, which is generally accorded great respect. The positive, categorical, and consistent identification of Caoile by prosecution witnesses Baarde and Quiambao, who knew him as a schoolmate, prevails over his bare denial and unsubstantiated alibi. The Court reiterated that between affirmative testimonies and negative denials, the former deserves more credence. For alibi to succeed, it must be shown that the accused was so far away that it was physically impossible for him to be at the crime scene. Caoile’s claimed location in Bataan was not proven to be an insurmountable distance from Manila, failing this stringent requirement.
Regarding the missing transcripts, the Court found the argument unmeritorious. Appellant inconsistently claimed the missing portions were both crucial and non-crucial. The Court determined that, based on the available records, the missing notes would have only corroborated the prosecution’s case, as the trial court’s decision indicated the testimonies were supportive of the eyewitness accounts. The established facts clearly demonstrated conspiracy and treachery, as the attack was sudden and employed means that ensured the victim had no opportunity to defend himself. The penalty was affirmed with modification, increasing the civil indemnity to P50,000.00.