G.R. Nos. L-32246-48 June 30, 1988
Arcadio Cortez y Vengzon and Paulino Sampang y Bungue, petitioners, vs. The Court of Appeals and The People of the Philippines, respondents.

FACTS

Petitioners Arcadio Cortez and Paulino Sampang, along with Benjamin Villanueva, were charged with murder and frustrated murder for a nighttime attack on the house of Santiago Baltazar. The trial court convicted Cortez and Sampang of two counts of homicide for the deaths of Escolastica Pingol (Baltazar’s wife) and Luis Baltazar (their son), and one count of less serious physical injuries for wounding Santiago Baltazar. Villanueva was acquitted. The Court of Appeals affirmed the convictions but increased the civil indemnity. The Supreme Court review was sought, with petitioners challenging the credibility of the lone eyewitness, Santiago Baltazar, and the admissibility of their extrajudicial confessions.
The prosecution’s case, as affirmed by the appellate court, established that on the night of October 21, 1961, Santiago Baltazar was awakened by dogs barking. He recognized the voices of Cortez and Sampang outside. Upon going down, he was shot and wounded. He later regained consciousness to find his wife and son dead. He identified Cortez and Sampang as the assailants, having known them prior and recognizing them under bright moonlight. Petitioners also executed extrajudicial confessions admitting to the shooting, claiming they targeted the family due to a belief the wife was a witch. They defended themselves with alibis, claiming they were elsewhere that night.

ISSUE

The core issue is whether the guilt of petitioners Arcadio Cortez and Paulino Sampang for the crimes of homicide and less serious physical injuries was proven beyond reasonable doubt.

RULING

The Supreme Court denied the petition and affirmed the convictions. The legal logic proceeds from the evaluation of evidence. First, the Court upheld the credibility of eyewitness Santiago Baltazar. His positive identification of the petitioners, whom he had known beforehand, was deemed credible and reliable. The Court found no improper motive for him to falsely accuse the petitioners, and his testimony withstood the test of cross-examination. The defense of alibi was correctly rejected. For alibi to prosper, it must be demonstrated that it was physically impossible for the accused to be at the crime scene. Here, the places cited in the alibis were within walking distance of the crime scene, negating any claim of physical impossibility.
Second, the Court ruled that the extrajudicial confessions were admissible and voluntary. Petitioners claimed they were coerced, but the Court found the confessions contained details only the perpetrators would know, indicating voluntariness. Furthermore, the corpus delicti—the fact that a crime was committed—was sufficiently established through the death certificates and Baltazar’s testimony. With the corpus delicti proven, the confessions provided valid corroborative evidence for conviction. Even disregarding the confessions, the positive identification by Baltazar alone was sufficient to establish guilt beyond reasonable doubt. The Court modified only the civil indemnity, raising it to P30,000.00 for each homicide.