G.R. No. L-32858 August 19, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff, vs. ADRIANO SALAZAR and PABLITO MASONGSONG, accused. ADRIANO SALAZAR, accused-appellant.

FACTS

On the night of January 30, 1970, Agapito Comea, a barrio captain, was shot and killed while making copra at a kiln in Barrio San Vicente, General Luna, Quezon. The sole eyewitness was his wife, Fe Reyes-Comea. She testified that while she and her husband were working, illuminated by a de gasa lamp, she heard footsteps, turned, and saw appellant Adriano Salazar from a distance of about three arms’ length aiming and firing a gun at her husband’s back. She saw Pablito Masongsong standing behind Salazar. After the shooting, Salazar allegedly said, “Tayo na pare at patay na.” The autopsy confirmed the victim died from a gunshot wound to the back. The killing was allegedly motivated by the fact that the deceased was a principal witness in a theft case against Salazar’s wife.
Based on Fe’s sworn statement, a complaint for murder was filed against Salazar and Masongsong. After trial, the Circuit Criminal Court convicted Salazar of murder and sentenced him to reclusion perpetua, while acquitting Masongsong due to insufficient evidence. Salazar appealed, challenging the eyewitness identification, suggesting the victim had other enemies, and asserting an alibi.

ISSUE

The crucial issue is whether the testimony of the lone eyewitness, Fe Reyes-Comea, is sufficient to sustain the conviction of appellant Adriano Salazar for murder beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The legal logic centers on the credibility of the eyewitness testimony and the weakness of the defense of alibi. The Court upheld the trial court’s finding that Fe’s testimony was clear, positive, and credible. The conditions for a reliable identification were present: the crime scene was illuminated by a lamp, the assailant was well-known to the witness, she was proximate to the event, and she promptly identified Salazar to the police hours after the incident. This prompt identification negated any possibility of fabrication or honest mistake.
Conversely, the Court found Salazar’s alibi unavailing. For an alibi to prevail, it must be shown that it was physically impossible for the accused to have been at the crime scene. Salazar’s house was only about 500 meters from the kiln, a distance he could traverse in half an hour or less. This did not constitute physical impossibility. The positive identification by a credible witness, which the Court found more compelling, therefore prevails over a weak alibi. The alleged existence of other enemies of the victim is irrelevant, as the prosecution successfully proved Salazar’s guilt through direct evidence. The decision underscores the principle that positive identification, when credible, is sufficient for conviction.