G.R. No. L-70223. March 31, 1987.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DONATO PETIL and BONIFACIO LUMANGLAS (At Large), accused, DONATO PETIL, accused-appellant.

FACTS

Accused-appellant Donato Petil and his co-accused Bonifacio Lumanglas were charged with murder for the killing of Fortunato del Valle on February 4, 1979, in Bay, Laguna. Lumanglas remained at large, so trial proceeded solely against Petil. The prosecution evidence, primarily from eyewitness Cesar Natividad, established that on the evening of the incident, the victim alighted from a vehicle to buy cigarettes. He was met by Petil and Lumanglas. Petil placed his arm around del Valle’s neck, and while holding him, Lumanglas stabbed the victim several times from the front. Prosecution witness Natividad also testified that he saw Petil stab the victim at the back. The wounded del Valle was rushed to the hospital but died.
Petil interposed the defense of alibi and denial. He claimed he was supervising work at a construction plant about 250 meters away when the stabbing occurred. He alleged that after an earlier altercation where del Valle pushed him, he was informed by a companion that Lumanglas had stabbed del Valle, prompting him to flee the area out of fear of retaliation. He further claimed he was later tortured by peace officers and relatives of the victim to extract a confession.

ISSUE

The core issue is whether the trial court erred in convicting Petil of murder based on the evidence presented, specifically in giving credence to the prosecution’s eyewitness account over his defense of alibi and in finding conspiracy between him and Lumanglas.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s factual findings, emphasizing that the assessment of witness credibility is best left to the trial judge. The positive identification of Petil by eyewitness Natividad, who saw him hold and stab the victim, was deemed credible and conclusive. The defense of alibi was correctly rejected. For alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of being at the crime scene. The distance of 250 meters did not constitute such impossibility. Alibi cannot prevail over positive identification.
Furthermore, the Court ruled that conspiracy was sufficiently established. Direct proof of a prior agreement is not essential; conspiracy can be inferred from the conduct of the accused before, during, and after the crime. The acts of Petil and Lumanglas—Petil holding the victim from behind while Lumanglas stabbed from the front, following an earlier confrontation between Petil and the victim—demonstrated a unity of purpose and concerted action to kill del Valle. Their relationship as brothers-in-law and the synchronized nature of the attack supported the finding of conspiracy, making Petil equally liable for the murder. The penalty of reclusion perpetua and the awarded damages were thus affirmed.