G.R. No. L-48085. June 26, 1991.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TEODORO CARCEDO y CARREDO, defendant-appellant.

FACTS

The accused, Teodoro Carcedo, was charged with Murder, while his co-accused Milagros Camahalan (the victim’s wife) was charged with Parricide, for the killing of Pedro Camahalan on May 21, 1977, in Malabuyoc, Cebu. The information alleged conspiracy among the accused. The prosecution presented evidence that Milagros, unable to bear her husband’s maltreatment, solicited Elisardo Carcedo to kill Pedro. On the night of the crime, eyewitness Alma Licaros saw Milagros, Pedro, and Elisardo together. The next day, Pedro’s body was found on a secluded beach with fatal head injuries inflicted with a bottle and stones. Simplicio Daplas testified that Milagros had earlier approached him looking for Elisardo and confessed her plan to have her husband killed.
Teodoro Carcedo interposed the defense of alibi, claiming he was fishing and sleeping at a different location within the same barrio on the night of the crime. The trial court convicted him of Murder, sentenced him to reclusion perpetua, and ordered him to pay indemnity. Teodoro appealed, challenging the trial court’s findings.

ISSUE

Whether the trial court erred in convicting Teodoro Carcedo of Murder based on the evidence presented and in rejecting his defense of alibi.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the evidence and witness credibility, noting that appellate courts generally defer to such factual findings. The defense of alibi was correctly rejected as inherently weak and unsubstantiated. For alibi to prosper, the accused must prove it was physically impossible for him to be at the crime scene. Here, Teodoro admitted he was fishing in Barrio Montanesa, which was only a short distance from where the killing occurred, negating any claim of physical impossibility. His own testimony corroborated the prosecution’s narrative that he was present in the general area and even interacted with the victim’s group earlier.
Furthermore, the Court found his alibi bore earmarks of fabrication. His conduct, which included two attempts to flee from authorities, was considered indicative of guilt. The evidence sufficiently established conspiracy; the acts of Milagros in soliciting the killing and Teodoro’s presence and participation, as inferred from the circumstances, showed a community of criminal design. The qualifying circumstance of treachery was present, as the attack from behind with a bottle rendered the victim defenseless. The decision was affirmed with the modification of increasing the civil indemnity to P50,000.00.