G.R. Nos. L-49859-60 February 20, 1986
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALEJANDRO VALENTINO y TOLENTINO, defendant-appellant.

FACTS

On May 21, 1971, at a cockpit in Batangas City, accused-appellant Alejandro Valentino shot Vicente Berberabe three times. Berberabe sustained fatal gunshot wounds, fracturing his mandible and causing internal injuries, and died at the hospital that same afternoon. During the shooting, a stray bullet also hit vendor Pacita Bulaklak, who died the following day from a gunshot wound to the head. The prosecution presented eyewitnesses Jose Ejes and Severino Asi, who positively identified Valentino as the gunman firing at close range.
The accused-appellant denied involvement and interposed the defense of alibi, claiming he was in San Miguel, Bulacan, on the day of the incident. The trial court convicted him of Murder for the death of Berberabe and Homicide for the death of Bulaklak, imposing respective prison terms and indemnities. The Intermediate Appellate Court later reviewed the penalties and certified the case to the Supreme Court.

ISSUE

The primary issue is whether the trial court erred in convicting the accused-appellant based on the eyewitness testimonies, despite the defense of alibi and alleged inconsistencies in the witnesses’ accounts.

RULING

The Supreme Court affirmed the conviction with modifications. The Court held that the positive identification by eyewitnesses Ejes and Asi, who were near the appellant during the shooting, prevails over the weak defense of alibi. The Court emphasized that alibi cannot stand against clear and credible positive identification. The alleged inconsistencies in the witnesses’ testimonies pertained only to minor details, which do not undermine their overall credibility but instead indicate spontaneous narration. The trial court, which observed the witnesses’ demeanor, found them testifying in a straightforward and sincere manner without any ill motive against the appellant.
Regarding the crimes, the killing of Berberabe was correctly classified as Murder, qualified by treachery, as the attack was sudden and afforded the victim no chance to defend himself. The death of Bulaklak, an unintended victim, constituted Homicide. The Court modified the penalties: for Murder, the proper penalty is reclusion perpetua; for Homicide, the maximum period of the indeterminate sentence was adjusted. The indemnity to the heirs of each victim was increased to P30,000.00. Thus, the judgment was affirmed with these modifications.