G.R. No. L-56283. June 30, 1987.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RUBEN ORNOZA and MARIO ORNOZA, defendants-appellants.

FACTS

The accused-appellants, brothers Ruben and Mario Ornoza, were charged with the murder of Virgilio Bayanin on September 10, 1977, in Candelaria, Quezon. The prosecution’s case rested primarily on the eyewitness account of Jesus Rebistual, a companion of the victim. Rebistual testified that while he and Bayanin were walking home from a social gathering, the appellants suddenly attacked Bayanin on a dark pathway. He saw Ruben beat the victim on the forehead with a hard object while Mario stabbed him in the chest. The dying victim was heard to exclaim, “Ano baga ang pagkakasala ko sa inyo, Mario, Ruben, bakit ninyo ako ginaganito?” Another witness, Efren Bayanin, the victim’s brother, testified that he later overheard the appellants conversing, with Ruben asking about Bayanin’s condition and Mario replying, “Siguradong patay na iyon.” The defense consisted of alibi, with the appellants claiming they were attending a birthday party at a relative’s house at the time of the incident.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellants beyond reasonable doubt, thereby overcoming their defense of alibi.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the weakness of alibi against positive identification and corroborative evidence. The Court emphasized that alibi is inherently unreliable and cannot prevail over the clear, positive, and credible testimony of eyewitnesses who identified the appellants as the perpetrators. The trial court correctly found the testimony of Jesus Rebistual to be convincing and unshaken. Furthermore, the victim’s dying declaration, uttered in a state of nervous excitement, formed part of the res gestae and was admissible to establish the identity of his assailants. The appellants’ flight from Candelaria immediately after the incident was also considered indicative of guilt. The Court found motive in the appellants’ desire for vengeance, as the deceased had previously been convicted for killing their father. The defense failed to demonstrate that it was physically impossible for the appellants to have been at the crime scene, a requisite for a successful alibi. Consequently, the trial court’s finding of guilt for murder, qualified by treachery, was upheld. The penalty of reclusion perpetua was affirmed, with the civil indemnity increased to Thirty Thousand Pesos.