G.R. No. L-29581-82 October 30, 1974
People of the Philippines, plaintiff-appellee, vs. Juan Ancheta, Pablito Ancheta, and Julian Bunay, accused; Juan Ancheta, defendant-appellant.

FACTS

In the early morning of May 5, 1967, Josefa Aglibut was awakened in her home in Lagangilang, Abra, by intruders. By the light of a lamp, she positively identified appellant Juan Ancheta, armed with a club, and his companion Pablito Ancheta, armed with a bolo. The two immediately attacked her sleeping husband, Braulio Aglibut; Juan clubbed him while Pablito stabbed him, causing his death. When Josefa grappled with them, she was also clubbed and boloed, sustaining injuries. Based on her prompt identification, Juan Ancheta was arrested. A criminal complaint for murder and frustrated murder was filed. Co-accused Pablito Ancheta and Julian Bunay jumped bail and remained at large, leaving Juan Ancheta as the sole appellant.
The defense interposed was alibi. Appellant claimed he was in Lacub, Abra, over 35 kilometers away, on the date of the crime. He and his father testified they were vendors traveling from Lacub. However, on cross-examination, the father could not recall subsequent travel dates, and another defense witness admitted he never reported appellant’s alleged whereabouts to any authority even after learning of appellant’s arrest for the Lagangilang crime.

ISSUE

The core issue is whether the trial court erred in convicting appellant Juan Ancheta based on the eyewitness testimony of Josefa Aglibut, despite the defense of alibi and alleged inconsistencies in her testimony.

RULING

The Supreme Court affirmed the conviction, with modifications to the civil indemnity and penalty. The Court found no error in the trial court’s reliance on the positive identification by the eyewitness. The legal logic centers on the weakness of alibi against positive identification and the assessment of witness credibility. The Court ruled that alibi is inherently weak and easily fabricated; it cannot prevail over the clear, positive, and credible testimony of a witness who has no motive to falsely testify. Appellant’s own admission that he was well-known to Josefa Aglibut as a townmate bolstered her capacity for accurate identification.
Regarding the alleged inconsistencies in Josefa’s testimony, the Court held that discrepancies on minor details do not undermine credibility but may instead indicate a truthful, unrehearsed narration, especially from a witness with limited education. Her prompt revelation of the assailants’ identities, leading to swift arrest, demonstrated spontaneity and lack of ulterior motive. The Court also addressed and found no merit in appellant’s ancillary claims concerning the trial judge’s conduct, noting that a judge may question witnesses to clarify points, provided it does not deny a fair trial. Thus, the positive identification established guilt beyond reasonable doubt, rendering the alibi defense unavailing.