GR L 44461; (April, 1988) (Digest)
G.R. No. L-44461 April 15, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CEFERINO MANUEL, LUIS EUGENIO, RANULFO ATILANO @ FELIPE ATILANO, SEGUNDINO ANDRES @ “DITO”, FELIPE RAMILLANO and ENRIQUE MANUEL, accused, CEFERINO MANUEL, SEGUNDINO ANDRES and LUIS EUGENIO, accused-appellants.
FACTS
On the night of January 24, 1972, thirteen members of the Alfaro family were attacked while asleep in their house in Zamboanga City. Armed intruders entered through a window and a loose kitchen board, hacking and stabbing the victims. The assault resulted in the deaths of five individuals and serious injuries to seven others. Only one family member escaped unharmed. Following a police investigation, an information was filed charging Ceferino Manuel, Luis Eugenio, Ranulfo Atilano, Segundino Andres, Felipe Ramillano, and Enrique Manuel with multiple murder and multiple frustrated murder.
At trial, the accused commonly interposed the defense of alibi. The Court of First Instance convicted Ceferino Manuel, Luis Eugenio, and Segundino Andres as principals, imposing five death penalties and seven prison terms for each, while acquitting the three other accused on reasonable doubt. The case is now on automatic review due to the imposition of the death penalty. Luis Eugenio, who escaped during trial, remains at large.
ISSUE
The core issue is whether the trial court erred in convicting the appellants based on the identification evidence presented by the prosecution and in rejecting their defense of alibi.
RULING
The Supreme Court affirmed the convictions but modified the penalties. The Court found the identification evidence against the appellants credible and sufficient. The appellants argued that the witnesses’ identifications were inconsistent with their earlier statements, making them unreliable. The Court meticulously reviewed these claims. For instance, regarding Celia Alfaro’s identification of Segundino Andres, the Court noted her initial description of the assailant as “tall and dark” was consistent with Andres’s appearance and explained by the fact she knew him only by face initially. Her subsequent positive courtroom identification was deemed a natural clarification, not a fabrication.
Similarly, the Court upheld the probative value of Ernesto Alfaro’s “ante-mortem” statement, given while he was in critical condition, as a dying declaration possessing inherent credibility. The positive identifications by multiple surviving victims, who knew the appellants prior to the incident, were found to be categorical and consistent on material points, outweighing the weak defense of alibi. The Court reiterated the doctrine that alibi cannot prevail over positive identification, especially when the alleged whereabouts were not so far as to preclude the appellants’ presence at the crime scene.
Consequently, the guilt of the appellants was established beyond reasonable doubt. However, for lack of the necessary votes to impose the death penalty, the Court reduced the five death sentences for each appellant to reclusion perpetua. It also increased the civil indemnity to the heirs of each deceased victim to P30,000.00. The prison terms were to be served simultaneously, not exceeding forty years. The judgment against Luis Eugenio, tried in absentia, remains enforceable upon his apprehension. The decision of the trial court was affirmed with these modifications.
