GR L 39335; (March, 1983) (Digest)
G.R. No. L-39335. March 25, 1983.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DAVID MENDOZA and ROMAN DE VERA, defendants, DAVID MENDOZA, defendant-appellant.
FACTS
The appellant, David Mendoza, was charged with Murder for the killing of Marte Flores on March 13, 1972, in Subic, Zambales. Prosecution witnesses Magtanggol Flores, Santiago Flores, and Fernando Abegania testified that around midnight, two jeeps carrying about 15 armed men arrived at their compound. Mendoza, leading the group, approached and asked for Marte Flores. Upon Marte identifying himself, Mendoza immediately shot him and fired three more shots at the fallen victim. Before leaving, Mendoza threatened the witnesses with death if they reported the incident. The witnesses identified Roman de Vera, the barrio captain, as being present in one jeep. The post-mortem examination confirmed the victim died from multiple gunshot wounds.
The defense interposed an alibi. Mendoza claimed he was in Floridablanca, Pampanga, from March 10 to 15, 1972, to sell his house, and only learned of the killing upon his return. His testimony was corroborated by the alleged buyer, Moises de Leon, and a neighbor, Marciana Masiclat. The defense also presented Francisco Rosete, who claimed he and another were the actual companions of the victim that night, not the prosecution witnesses.
ISSUE
The core issue is whether the prosecution evidence sufficiently established the guilt of David Mendoza for Murder beyond reasonable doubt, overcoming his defense of alibi and challenges to witness credibility.
RULING
The Supreme Court affirmed the conviction. The Court found the testimonies of the prosecution witnesses credible and convincing. Their narration of the event was clear, consistent, and detailed. The Court noted that Magtanggol Flores was a minister, whose moral character made his testimony highly reliable. The witnesses’ initial failure to report the crime immediately was reasonably explained by the real and forbidding threat from the armed group, which included the barrio captain. This delay did not impair their credibility, especially as they came forward when conditions improved after martial law was declared.
Conversely, the defense of alibi was rejected as inherently weak and unworthy of belief. Floridablanca, Pampanga, was merely two hours away from the crime scene, making it physically possible for Mendoza to have committed the crime and returned. The Court found the defense narrative illogical, questioning why Mendoza would abandon his pregnant wife and livelihood for five days to wait for a small payment, and why his alibi witness would constantly accompany him, neglecting his own duties. The positive identification by credible eyewitnesses prevails over a dubious alibi. The qualifying circumstance of treachery was present, as the attack was sudden and deliberate, giving the victim no opportunity to defend himself. The penalty of reclusion perpetua and the indemnity were thus upheld.
