G.R. No. 95685 ; March 4, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DENNIS DE GUZMAN y DE LEON, accused-appellant.

FACTS

On March 19, 1986, accused-appellant Dennis de Guzman confronted Efren Pangilinan for allegedly cheating in a card game during the wake of de Guzman’s grandmother. A fight ensued. Eleven days later, on March 30, 1986, at around 3:00 a.m., Leonardo Pangilinan, Efren’s brother, was in front of a store when four men, including de Guzman, approached him. After asking if he was Efren, one of the men shot Leonardo. Two more shots were fired, with de Guzman and another identified as Carlito Porma hitting the victim. The victim, before dying, uttered the words “Hadji, Hadji, Apat apat.” Prosecution witnesses Gloria Pangilinan, Marcelina Yabis, and Emelita Sudla positively identified de Guzman as one of the assailants at the scene.
The defense presented an alibi, claiming de Guzman was at home sleeping at the time of the shooting. He asserted that the prosecution witnesses were biased due to family relations and that the initial police investigation did not name him. The trial court convicted de Guzman of murder qualified by treachery and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of Dennis de Guzman for Murder based on the credibility of the prosecution witnesses and the rejection of his alibi.

RULING

The Supreme Court affirmed the conviction. The positive identification by eyewitnesses, who had no improper motive to testify falsely, prevails over the defense of alibi. Gloria Pangilinan clearly saw the shooting from a close distance of four meters under sufficient illumination from a nearby lamppost and store light. Her testimony was corroborated by two other witnesses. The Court found no reason to doubt their credibility, noting that minor inconsistencies in their testimonies did not detract from their core consistency regarding de Guzman’s presence and participation.
The defense of alibi was properly rejected. For alibi to prosper, the accused must prove it was physically impossible for him to be at the crime scene. De Guzman’s claimed location was merely a few minutes away from the crime scene, negating any physical impossibility. Furthermore, proof of motive is not indispensable when there is positive identification, but the Court noted that the prior altercation with the victim’s brother provided sufficient motive for retaliation. The qualifying circumstance of treachery was correctly appreciated as the attack was sudden and from behind, rendering the victim defenseless. The decision was affirmed with modification, increasing the civil indemnity to P50,000.00.