G.R. No. L-19071 April 30, 1965
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RICARDO REYNO, defendant-appellant.

FACTS

The accused Ricardo Reyno was charged with and convicted of murder for the death of Noel Vigilia by the Court of First Instance of Nueva Ecija and sentenced to reclusion perpetua, indemnification, and costs. The fact of the stabbing death in the early morning of April 7, 1961, in Cabanatuan City is undisputed; the identity of the assailant is the principal issue. The prosecution’s case, primarily through witness Nicolas Ruiz, Jr., established that around 12:30 a.m., the deceased and his companions were at a store when they saw four persons, including the accused, tampering with a water pipe. The deceased told them to stop. Later, as the deceased’s group walked home, the deceased was stabbed. Ruiz, Jr. saw the assailant holding a bladed instrument about 2-3 meters away and, during a confrontation lasting about 40 seconds, recognized him as one of the persons who had tampered with the pipe, wearing the same attire (khaki trousers, T-shirt, buri hat). The assailant, identified as Reyno, fled with three others. The deceased died from severe hemorrhage. Police found Reyno acting suspiciously at a bus terminal. Ruiz, Jr. positively identified him there. A search of Reyno’s bag yielded a fan knife, and a blood-stained T-shirt was found at his sister’s house. NBI chemical analysis confirmed human blood on the knife, and the blood on the T-shirt matched the blood type of the deceased but differed from Reyno’s own blood type. The defense presented an alibi, claiming Reyno was at his sister’s house, and suggested the blood on the T-shirt was planted during investigation.

ISSUE

Whether the trial court erred in convicting the accused based on the identity of the assailant, despite the defense of alibi and challenges to the evidence.

RULING

The Supreme Court affirmed the conviction. The positive identification of the appellant by prosecution witness Ruiz, Jr., which was spontaneous and made shortly after the crime, was deemed credible and sufficient to establish identity. This identification was convincingly corroborated by the physical evidence: the blood-stained knife found in the appellant’s possession and the blood on his T-shirt, which chemically matched the blood type of the deceased. The appellant’s alibi could not overcome this positive identification. The Court also rejected the appellant’s claim that the blood was planted, deeming it preposterous. The argument regarding lack of motive was unavailing, as motive is not an essential element of a crime, and the Court noted the stabbing could have been prompted by resentment over the deceased’s earlier interference with the pipe-tampering. The decision of the trial court was affirmed in all respects.