G.R. No. L-2543; March 19, 1951
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAGONDACAN BURANSING, defendant-appellant.

FACTS

The defendant-appellant, Magondacan Buransing, was convicted of murder by the Court of First Instance of Lanao for shooting and killing his father-in-law, Rudi Gorodatu, and was sentenced to reclusion perpetua. The prosecution presented two eyewitnesses: Panotolan Kabasaran (the victim’s wife), who testified that at midnight on January 3, 1948, she saw the appellant shoot her sleeping husband from the window of their house in Bayang, Lanao; and Makarungon Diwan (a neighbor), who testified that immediately after hearing the shot, he saw the appellant carrying a rifle and running from the victim’s house. The prosecution’s evidence indicated the motive was the appellant’s resentment because Rudi Gorodatu refused to compel his own daughter (the appellant’s wife, Binakaran) to return to the appellant after a marital quarrel and had scolded the appellant for punishing his wife. The appellant interposed the defense of alibi, testifying that he slept that night in the house of Toroganan Saikaman, located four kilometers away, because it was raining and he was collecting a debt, a testimony corroborated by Toroganan Saikaman. The defense also attacked the credibility of the prosecution witnesses, pointing out alleged inconsistencies and motives for falsifying testimony.

ISSUE

The main issue is whether the trial court erred in convicting the appellant based on the credibility of the prosecution witnesses over the appellant’s defense of alibi and challenges to the witnesses’ testimonies.

RULING

The Supreme Court affirmed the conviction, upholding the trial court’s findings on witness credibility. The Court held that the positive identification by the eyewitnesses, who had no proven motive to testify falsely against the appellant, prevailed over the defense of alibi. The Court found the appellant’s alibi weak and not airtight, as the house where he claimed to be was only four kilometers from the crime scene, making it possible for him to have committed the crime. The Court addressed the alleged inconsistencies in the prosecution witnesses’ testimonies, considering them minor or explained (e.g., a witness’s miscalculation of distance or time). The Court found the appellant’s motive—resentment over his father-in-law’s refusal to intervene in his marital dispute—to be credible. The crime was qualified as murder, with the aggravating circumstance of dwelling. However, applying Section 106 of the Administrative Code for the defunct Department of Mindanao and Sulu, the penalty of reclusion perpetua imposed was within legal limits. The Court modified the judgment only by increasing the indemnity to the heirs of the deceased from P2,000 to P6,000.