G.R. No. L-59546 July 25, 1983
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VICENTE CASAS, WENCESLAO PALARCA, JAIME RODRIGUEZ, and GREGORIO OCLARIT, accused-appellants.

FACTS

An information for murder was filed against Vicente Casas, Wenceslao Palarca, Jaime Rodriguez, and Gregorio Oclarit for the killing of Rogelio Abugho on December 17, 1976, in Gingoog City. The prosecution alleged that the accused, conspiring together and armed with a bolo, attacked the victim with treachery and abuse of superior strength. The trial court convicted all four accused of murder qualified by abuse of superior strength and sentenced each to reclusion perpetua. Palarca, Rodriguez, and Oclarit subsequently withdrew their appeals, leaving only Vicente Casas as the appellant before the Supreme Court.
The prosecution’s primary witness, Santo Enciso, testified that he was with the victim buying household items. As they left the store, they encountered the accused. Rodriguez signaled the victim’s presence, Oclarit shouted “Kill him,” Palarca pinned the victim’s arms from behind, and Casas then stabbed Abugho in the abdomen with a bolo, causing his death. The motive was established as a land dispute, wherein the accused, having been driven off land the victim was working on, held a grudge. Casas interposed the defense of alibi, claiming he was in Gingoog City obtaining a police clearance at the time of the killing.

ISSUE

The core issue is whether the trial court erred in giving credence to the testimony of prosecution witness Santo Enciso, thereby convicting appellant Vicente Casas of murder.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, finding no reason to deviate from its conclusions. Santo Enciso’s testimony was clear, positive, and straightforward, providing a coherent narrative of the conspiracy and the fatal stabbing. His account was corroborated by the testimony of Patrolman Godofredo Cabana, who stated that Casas had admitted to the stabbing during the police investigation. While Casas later claimed this admission was coerced, he presented no evidence to substantiate this claim of duress.
The defense of alibi was rejected as inherently weak and could not prevail over Enciso’s positive identification of Casas as the perpetrator. The Court emphasized that for alibi to succeed, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of his being at the crime scene. Casas failed to meet this burden. Furthermore, the established motive—the land dispute—lent credence to the prosecution’s version of events. The Court found that the killing was attended by abuse of superior strength, as the victim was restrained by Palarca before being stabbed by Casas, rendering him defenseless. The judgment of the trial court was therefore affirmed in toto.