G.R. No. L-15369; April 26, 1962
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TIMOTEO CRUZ alias CAPT. TOMMY, FELIPE DE LA CRUZ alias PHILIP, JOHN DOE and RICARDO DOE, defendants-appellants.

FACTS

In the early morning of August 9, 1955, Manuel Valencia was shot and killed while at a fruit stand on Azcarraga Street, Manila. The lone eyewitness, Eliseo Cruz, testified that as Valencia turned his head, appellant Felipe de la Cruz shot him at close range from behind. A second shot was fired from the direction of the railroad tracks in the middle of the street, where appellant Timoteo Cruz was seen standing with a drawn gun. When Felipe’s pistol jammed as he aimed at Eliseo, Eliseo fled and reported the crime to nearby policemen. Valencia died from his injuries. Corroborative testimony established that immediately after the shooting, two men ran and boarded a car, identified as belonging to Timoteo Cruz, which sped away. One man was heard stating his gun had jammed.
Appellants denied involvement. Felipe de la Cruz presented an alibi, claiming he was at home from 9:00 p.m. the previous night until 6:00 a.m. the next morning, seeking blood for his stepfather’s operation. The defense presented witnesses to corroborate his whereabouts. Timoteo Cruz did not specifically deny his presence near the crime scene, as police testimony placed his car in the vicinity around the time of the shooting.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt the identity of the appellants as the perpetrators of the murder of Manuel Valencia.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the credibility of the prosecution’s eyewitness and corroborative evidence, which overwhelmingly established the appellants’ guilt. The Court found Eliseo Cruz’s testimony clear, consistent, and credible. His identification of Felipe de la Cruz as the gunman who shot Valencia from behind was corroborated by Sgt. Redolfin, who saw Felipe in the area just before the shooting. The presence and participation of Timoteo Cruz were confirmed by Eliseo, who saw him with a drawn gun at the railroad tracks immediately after the first shot, and by witnesses Zamora and Leyva, who saw his car used for the getaway with Felipe boarding it.
The Court rejected Felipe’s alibi as weak and unpersuasive. It was physically possible for him to have been at the crime scene given the proximity of his home to Azcarraga Street. The positive identification by credible witnesses prevails over an alibi that is not airtight. The collective evidence demonstrated conspiracy through their coordinated actions: Felipe’s direct attack, Timoteo’s supporting gunfire, and the use of Timoteo’s car for escape. The killing constituted murder qualified by treachery, as Valencia was shot from behind without warning, eliminating any chance for defense. The penalty was life imprisonment for both, with Felipe, a recidivist, receiving a harsher sentence consideration, though not the death penalty due to insufficient votes.