G.R. No. L-17772; October 31, 1962
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PEDRO BAUTISTA, ET AL., defendants-appellants.

FACTS

The appellants, Pedro Bautista, Felipe Bautista, Alberto Bautista, Roman Bautista, and Mariano Baticos, were convicted of murder for the killing of Crisanto Ponyo. The prosecution’s eyewitness, Juanito Hernandez, testified that on a moonlit night, he saw the five accused, armed with bladed weapons and an iron bar, surround the victim. Despite the victim’s pleas, Felipe struck him with an iron bar, after which the others collectively stabbed him, causing his death. This account was corroborated by another witness, Alfonso Corlit. The post-mortem examination revealed multiple fatal wounds caused by sharp and blunt instruments.
Appellant Pedro Bautista presented a different version, claiming he acted alone in self-defense. He alleged that the victim, who bore ill will towards him, initiated a sudden attack with a balisong knife. After a struggle, Pedro wrested the knife and stabbed the victim multiple times. He then surrendered to authorities. The other appellants merely interposed the defense of alibi, claiming they were at their respective homes during the incident.

ISSUE

The core issue is whether the trial court correctly convicted the appellants of murder, rejecting Pedro Bautista’s claim of self-defense and the alibi defenses of the others.

RULING

The Supreme Court affirmed the convictions, upholding the trial court’s findings. The Court meticulously dismantled the defenses presented. Regarding Pedro Bautista’s claim of self-defense, the Court found his narrative inherently unbelievable and incompatible with the legal requirements of self-defense. His admission that he continued to stab the victim seven times after allegedly disarming him demonstrated a clear intent to kill, not merely to defend himself. This excessive force negated any claim of reasonable necessity.
The Court also gave no credence to the alibi defenses of the other appellants. Alibi is a weak defense that must be established by clear and convincing evidence, demonstrating the physical impossibility of the accused’s presence at the crime scene. The appellants failed to meet this burden. Their alibis were unsupported and could not overcome the positive, credible, and consistent identification by two eyewitnesses who knew them well. The relationship of the witnesses to the victim does not automatically discredit their testimony, especially when, as here, their accounts were detailed and corroborated by physical evidence.
The collective manner of the attack, with multiple armed assailants surrounding a single victim, properly justified the trial court’s finding of abuse of superior strength, qualifying the killing as murder. The penalty imposed was thus affirmed, with the case against Roman Bautista dismissed due to his death pending appeal.