G.R. No. L-68331. January 29, 1988.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSE SANTILLAN, accused-appellant.

FACTS

The prosecution’s evidence established that on the night of September 9, 1979, in Barangay Bagong Pook, Sta. Maria, Laguna, Rodolfo Acelajado witnessed appellant Jose Santillan and his son-in-law Alex Pagapos (at large) hacking the unarmed Domingo Era with bolos in a ricefield. The victim sustained fourteen fatal stab and incised wounds. Acelajado, familiar with both assailants for five years and positioned fifteen meters away under moonlight, positively identified them. His testimony was corroborated by Vicente Recipide. Both witnesses testified naturally to the events they saw while passing by, with no evidence of improper motive against them.
The defense centered on assailing the credibility of these two prosecution witnesses, arguing their testimonies were incredible. Appellant also interposed an alibi, claiming he was elsewhere at the time of the incident. The trial court convicted Santillan of Murder, sentencing him to reclusion perpetua and ordering indemnity and damages. Santillan appealed, contesting the trial court’s findings on witness credibility and the rejection of his alibi.

ISSUE

Whether the trial court erred in convicting the accused-appellant of Murder based on the credibility of the prosecution witnesses and in rejecting his defense of alibi.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s assessment of witness credibility, giving it great respect as it is supported by the record. The testimonies of Acelajado and Recipide were found natural, straightforward, and credible. There was no evidence to suggest they were actuated by ill motive, and the presumption remains that they were not. The failure to present other listed witnesses did not impair their credibility, considering the co-accused remained at large, which could understandably deter others from testifying.
The defense of alibi was correctly rejected. Alibi is inherently weak and easily fabricated. For it to prosper, the accused must prove not only his presence elsewhere but also the physical impossibility of being at the crime scene. Santillan’s uncorroborated claim failed this test, as the distance between his alleged location and the crime scene was negotiable within minutes. His alibi crumbled in the face of the positive and credible identification by the prosecution witnesses.
However, owing to the abolition of the death penalty under the 1987 Constitution, the penalty for Murder was reduced. With no modifying circumstances, the imposable penalty is within the range of reclusion temporal maximum to reclusion perpetua. Applying the Indeterminate Sentence Law, the Court modified the sentence to an indeterminate penalty of ten years and one day of prision mayor, as minimum, to eighteen years, eight months and one day of reclusion temporal, as maximum. The civil indemnity was increased to P30,000.00.