G.R. No. L-68805 July 9, 1986
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENJAMIN CRUZ, accused-appellant.

FACTS

Accused-appellant Benjamin Cruz was convicted of Murder by the Regional Trial Court of Caloocan City for the fatal shooting of Salvador de Castro on June 30, 1966. The prosecution established that at around 7:00 a.m., the victim was a passenger in a jeepney driven by Domingo Cruz. Eyewitness Oscar Rustia, also a passenger, testified that the appellant, whom he knew as “Amen,” boarded the jeepney, concealed a gun, and later shot de Castro at close range near Quintos Street, Navotas. Rustia positively identified the appellant as the assailant. The jeepney driver corroborated the incident, stating he heard a shot and discovered his passenger wounded. The victim died from a gunshot wound to the head, as detailed in the necropsy report.
The defense consisted of an alibi, with appellant claiming he was in Bambang, Bulacan, working as a banca maker at the time of the crime. He denied involvement and asserted mistaken identity. The trial court found the prosecution’s evidence, particularly the positive eyewitness identification, credible and convincing, leading to a judgment of conviction and a sentence of reclusion perpetua, along with an indemnity order.

ISSUE

Whether the trial court erred in convicting the accused-appellant based on the prosecution’s evidence and in not giving credence to his defense of alibi.

RULING

The Supreme Court affirmed the conviction, finding no merit in the appeal. The legal logic centers on the strength of positive identification over alibi. The Court held that the testimonies of eyewitness Oscar Rustia and jeepney driver Domingo Cruz were straightforward, credible, and consistent, establishing appellant’s guilt beyond reasonable doubt. Rustia, who knew the appellant prior to the incident, provided a detailed account of the shooting, leaving no room for mistaken identity.
The defense of alibi was correctly rejected. Jurisprudence consistently rules that alibi cannot prevail over positive identification by credible witnesses. For alibi to prosper, it must be demonstrated with clear and convincing evidence that the accused was at another place for the entire period of the crime’s commission, making his presence at the scene impossible. Appellant failed to meet this strict standard. The distance of approximately thirty kilometers between Bambang, Bulacan, and Navotas did not preclude the possibility of his presence at the crime scene, given modern transportation. The trial court’s assessment of witness credibility is accorded great respect, and the appellant did not show any substantial reason to overturn it. The Court modified the civil liability by increasing the indemnity to the heirs of the deceased to P30,000.00, in line with prevailing jurisprudence.