G.R. Nos. L-66917-18 September 24, 1986
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ADRIANO AMONCIO y OLANTIGUE, EMEGDIO AMONCIO y OLANTIGUE and SILVESTRE AMONCIO y TAGLE, accused-appellants.

FACTS

Two separate informations were filed against the accused-appellants for Murder and Frustrated Murder stemming from the same incident on November 29, 1981. The prosecution evidence established that after a cockpit event in Pilar, Bohol, the victim Pablito Perocho and Jose Aboabo were walking together with appellant Adriano Amoncio. Adriano suddenly shouted a pre-arranged signal, separated from the group, and stabbed Pablito from behind. In response to the shout, appellants Emigdio (Adriano’s brother) and Silvestre (their nephew) emerged from hiding. Emigdio stabbed Pablito at the back below the nape, while Silvestre stabbed Jose Aboabo on the chest. Adriano then also stabbed Jose. Pablito died from his wounds, while Jose survived after hospitalization.
The defense presented alibis and denial. Adriano claimed he merely witnessed a fight between the victims and others. Emigdio asserted he was harvesting rice six kilometers away, while Silvestre alleged he was working in Butuan City. The trial court convicted all appellants, sentencing Adriano and Emigdio to reclusion perpetua for Murder, and Adriano and Silvestre to prison terms for Frustrated Murder.

ISSUE

The core issue is the credibility of the prosecution witnesses versus the defenses of denial and alibi presented by the appellants.

RULING

The Supreme Court affirmed the convictions, upholding the trial court’s findings on credibility. The legal logic is anchored on the strength of positive identification over weak alibis. Jose Aboabo, a victim and eyewitness who had long known the appellants, provided clear and credible testimony identifying them as the assailants. His account was corroborated by other witnesses. The dying declaration of Pablito Perocho, identifying “Adring Amoncio” (Adriano) as his assailant, was admissible as it was made under a consciousness of impending death.
The appellants’ defenses were correctly rejected. Adriano’s denial was self-serving and unconvincing. The alibis of Emigdio and Silvestre were frail and insufficient to overcome the positive identification. For an alibi to prevail, it must be established by clear and convincing proof that the accused was so far away that they could not have been physically present at the crime scene. Here, the alibis were not only uncorroborated but were also contradicted by prosecution evidence, such as a witness who placed Emigdio near the crime scene. The Court reiterated the doctrine that the trial court’s assessment of witness credibility is entitled to great weight and respect on appeal. The judgment was affirmed, with the civil indemnity for the heirs of Pablito Perocho increased to P30,000.00.