People of the Philippines, plaintiff-appellee, vs. Alejandro Guzman, defendant-appellant.
FACTS
On the morning of August 29, 1953, in Sinait, Ilocos Sur, two young schoolboys, Eustaquio Ibuos (age 9) and Antonio Rosete (age 12), were gathering fruits in a tamarind tree. From their vantage point, they saw the accused, Alejandro Guzman, cutting shrubs nearby. They also saw the deceased, Patrocinia Ibuos, picking vegetables a short distance from the accused. The accused approached Patrocinia, placed an arm around her, and when she struggled and pushed him away, he grabbed her by the hair, pulled her to the ground, stabbed her below the neck with a short bolo, and slashed her throat. He then dragged her body to the edge of a precipice and fled. The boys reported the incident to the deceased’s grandmother. Authorities found the body at the reported location. An autopsy by Municipal Health Officer Dr. Jose Avelino confirmed the victim was pregnant and had died recently from severe shock and profuse hemorrhage due to stab and incised wounds on the neck. The accused was apprehended and charged with murder. At trial, the accused set up an alibi, claiming he never left the vicinity of his house that morning. His brother and a neighbor corroborated this. The trial court discredited the alibi, believed the testimony of the two young witnesses, convicted the accused of murder, and sentenced him to reclusion perpetua with indemnity.
ISSUE
Whether the trial court erred in convicting the appellant of murder based on the testimony of the young witnesses and in rejecting his defense of alibi.
RULING
The Supreme Court affirmed the conviction. The guilt of the appellant was established beyond reasonable doubt. The testimony of the two young witnesses was found credible, as they testified clearly and with no shown improper motive. Their account was corroborated by the immediate discovery of the body at the reported location and by the admission of the accused’s own brother that the accused had gone to gather “comcompitis” leaves that morning. The defense’s claims that the boys testified based on gossip or were coerced were unsupported by the record. The defense of alibi was inherently weak and not credible, as it was not physically impossible for the accused to have been at the crime scene. The crime was properly qualified as murder due to the circumstance of abuse of superior strength, as the attack was made by a man with a deadly weapon upon an unarmed and defenseless woman. With no aggravating or mitigating circumstances, the penalty of reclusion perpetua was in accordance with law.
