G.R. No. L-48255 September 30, 1983
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANIELITO DEMETERIO, ET AL., accused, DANIELITO DEMETERIO, accused-appellant.

FACTS

The accused-appellant, Danielito Demeterio, was charged with Murder for the killing of Rodolfo Saludes on March 27, 1971, in Gasan, Marinduque. The Information alleged conspiracy with Jeremias Bruit, employing treachery, evident premeditation, and abuse of superior strength. Bruit pleaded guilty to Homicide and died in prison. Demeterio pleaded not guilty. The prosecution’s eyewitness, Teresita Motol (the victim’s widow), testified that she saw Bruit and Demeterio chase her husband. Bruit was armed with a bolo and Demeterio with a pointed iron bar. They caught Saludes in a river, where Bruit held him and hacked him while Demeterio stabbed him, causing multiple fatal wounds. The post-mortem examination confirmed the cause of death.
The defense interposed alibi, claiming Demeterio was at home repairing their balcony during the incident. His sister corroborated this. The defense also presented police and barangay testimonies asserting that initial reports only implicated Bruit, not Demeterio. Witness Cirila Maac, who was with the widow, allegedly stated only Bruit was seen chasing the deceased, contradicting Teresita Motol’s account.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt, overcoming his defense of alibi and the alleged inconsistencies in the prosecution’s narrative.

RULING

The Supreme Court affirmed the conviction. The positive identification by eyewitness Teresita Motol, who had no ill motive to falsely testify, prevails over the defense of alibi and the alleged inconsistencies. The Court found her testimony clear and credible, detailing the concerted attack. The claim that initial reports only named Bruit does not exonerate Demeterio, as witnesses may initially be hesitant to name all assailants out of fear, and the information provided to authorities can be incomplete. The testimony of Cirila Maac, presented by the defense, was deemed insufficient to discredit the positive identification, especially as it was not formally offered as evidence for the prosecution.
The defense of alibi fails because it was not physically impossible for Demeterio to be at the crime scene, given that his house was only about half a kilometer away. Alibi is inherently weak and cannot stand against positive identification. The crime committed is Murder qualified by abuse of superior strength, as two armed assailants jointly attacked an unarmed victim in a river, ensuring he had no chance to defend himself. With no modifying circumstances, the penalty of reclusion perpetua imposed by the trial court is affirmed. The judgment is in accordance with law and evidence.