G.R. No. L-59951 June 24, 1983
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EMILIO AQUINO alias Edu, accused-appellant.

FACTS

In the early morning of April 17, 1981, Good Friday, Primitive Orines, his wife Erlinda, son Alfredo, and sister-in-law Flora were walking to hear mass in Manaoag, Pangasinan. While on the road in Barangay Jimenez, accused-appellant Emilio Aquino, holding a long firearm, followed them and shot Primitive Orines from behind, causing his instantaneous death. The eyewitnesses, who were only a few meters away, looked back and saw Aquino, whom they recognized as a familiar person from their barangay. Aquino fired two more shots, causing the witnesses to hide. He then approached the victim, divested him of his slippers, boots, belt, and wallet, and fled. The area was illuminated by moonlight and an electric lamp. The police were notified, and Aquino was arrested in his house a few hours later.
Aquino pleaded alibi, claiming he was at a wake in a house about two kilometers away from the crime scene during the entire period. His alibi was corroborated by the barangay captain and other officials. A paraffin test conducted on him five days after the incident yielded negative results for nitrates. The defense also highlighted alleged inconsistencies in the prosecution witnesses’ testimonies and the absence of a clear motive for the killing.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Emilio Aquino was the perpetrator of the killing, thereby rendering his defense of alibi unavailing.

RULING

The Supreme Court affirmed the conviction for murder. The Court upheld the trial court’s assessment of the credibility of the prosecution witnesses. The positive identification by Erlinda and Alfredo Orines, who knew Aquino personally and saw him clearly under adequate illumination from a short distance, prevailed over the defense of alibi. The Court emphasized that alibi is inherently weak and cannot stand against positive identification, especially where, as here, the distance between the crime scene and the place claimed for the alibi was merely two kilometers and could be negotiated in a short time, making it physically possible for Aquino to have committed the crime and returned.
The alleged discrepancies in the witnesses’ testimonies were deemed minor and did not affect their core narrative of the shooting and robbery. The negative paraffin test, conducted five days after the fact, was not conclusive proof of innocence, as nitrates could be removed by washing. While the evidence indicated that robbery was the immediate motive, making the crime technically robbery with homicide, the Court sustained the conviction for murder as that was the crime charged and proven by the prosecution. The absence of a deeply established motive was inconsequential, as the evidence of the criminal act itself was clear and convincing.