G.R. No. 93899. May 8, 1992
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDDIE CADAG Y CABOTAJE, alias “Simen”, accused-appellant.

FACTS

Accused-appellant Eddie Cadag was convicted by the Regional Trial Court of Rosales, Pangasinan, for the crime of Murder and sentenced to reclusion perpetua. The victim, Arnel Claridad, was found dead in the Far East High School compound in Sta. Maria, Pangasinan, on the morning of March 14, 1989. An investigation revealed a blood trail from the school gate to the body. The victim was last seen with Lorna Taguiped, the appellant’s common-law wife. Initially, Lorna executed a sworn statement to the NBI on March 30, 1989, denying any knowledge of the incident. However, after separating from the appellant, she executed another sworn statement on July 10, 1989, identifying the appellant as the assailant. At trial, Lorna testified that on the evening of March 13, 1989, the appellant, jealous of her former boyfriend Boyet Claridad, brought her to Boyet’s house. Boyet was not there, but his brother Arnel followed Lorna back. Upon reaching the Far East High School, the appellant emerged from the darkness and, without warning, stabbed Arnel multiple times, pursued him into the school compound, and continued stabbing him until he died. The medical certificate by Dr. Susan Casaclang detailed multiple stab wounds, lacerations, and fractures on the victim’s body. The appellant interposed alibi as his defense, claiming he was at home with Lorna and his mother the entire evening. His mother and a neighbor corroborated this. The trial court rejected the alibi and convicted the appellant of murder qualified by treachery.

ISSUE

Whether the trial court erred in convicting the accused-appellant of murder based on the credibility of the eyewitness testimony and in rejecting the defense of alibi.

RULING

The Supreme Court affirmed the conviction. The credibility of eyewitness Lorna Taguiped was upheld despite her two contradictory sworn statements, as she explained at trial that her initial statement was made under threat from the appellant. Proof of motive is not indispensable when the identity of the culprit is established, as Lorna definitively pinpointed the appellant as the killer, and her testimony was corroborated by physical evidence. The Court found it improbable that Lorna, lacking extraordinary strength, could have inflicted the multiple severe wounds on the victim. The appellant’s alibi was correctly rejected, as it was supported only by interested witnesses (his mother and neighbor) and the distance between his home and the crime scene did not preclude his presence there. The crime was murder qualified by treachery, as the appellant, armed with a knife and under cover of darkness, suddenly and unexpectedly attacked the unarmed victim. The indemnity was increased to P50,000.00 in line with prevailing jurisprudence.