G.R. No. L-51908 November 29, 1984
People of the Philippines vs. Bayani Jacinto y Valle alias “Boy Juaning”

FACTS

The accused, Bayani Jacinto, was charged with Murder for the stabbing of Wenifredo Bantigue at a billiard hall in Caloocan City on June 27, 1973. The victim sustained a deep stab wound at the back, which penetrated his spinal cord. He was hospitalized and gave a statement to Pat. Cesar Antonio that evening, identifying his assailant as “Boy Juaning.” The victim died fourteen days later from meningoencephalitis secondary to the infected spinal cord injury. The prosecution presented three eyewitnesses—Crisanta Zaplan, Nicolas Dionisio, and Joseronce Yecla—who positively identified Jacinto as the perpetrator who stabbed the victim and then fled.
The defense interposed alibi, claiming Jacinto was at his workplace in Novaliches, Quezon City, at the time of the incident. He argued that the victim’s ante-mortem statement was inadmissible as a dying declaration and that the eyewitness testimonies were unreliable due to their relationship with the deceased. He further contended that his own mother reported the stabbing to the police, which he claimed was unnatural if he were involved.

ISSUE

The core issues were: (1) the admissibility and weight of the victim’s ante-mortem statement; (2) the credibility of the prosecution eyewitnesses; and (3) the viability of the defense of alibi.

RULING

The Supreme Court affirmed the conviction. The victim’s statement was properly admitted as a dying declaration. The nature of the wound—a deep penetration of the vertebra and spinal cord—supported the conclusion that the declarant was conscious of his impending death when he identified “Boy Juaning,” notwithstanding the 14-day interval before his actual demise. This identification was also admissible as part of the res gestae, being a spontaneous statement made immediately after the startling event.
The positive identification by three eyewitnesses was deemed credible. Their familial relationship to the victim does not automatically impair their testimony, especially absent proof of improper motive. Minor inconsistencies in their accounts did not detract from their overall credibility. The defense of alibi failed because Jacinto admitted the crime scene was only a 30-minute jeepney ride from his workplace, making it physically possible for him to be present. Alibi cannot prevail over positive identification. The act of his mother in reporting the crime did not exonerate him, as her testimony revealed she did not witness the assailant. Finally, proof of motive is unnecessary where the accused is positively identified. The Court modified the judgment by increasing the civil indemnity to P30,000.00.