GR L 70255; (January, 1987) (Digest)
G.R. No. L-70255. January 29, 1987.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILBUR ABOGA Y EVANGELISTA alias “WILLY,” RODOLFO BAS NAVARRA alias “BOY ILONGGO” alias ‘BOY BRITANNICO and JOHN DOE alias “LITTLE BOY NAVARRA,” accused-appellants.
FACTS
The prosecution established that on the evening of August 21, 1979, a drinking session occurred at a store in Quezon City. Among the participants were accused Rodolfo Navarra and the victim, Emiterio Roquid, along with Reynaldo Pantinople. An argument arose between Navarra and Roquid, culminating in Pantinople boxing Navarra. Navarra left but later returned with a knife, though he did not immediately act. Later that night, Pantinople and Roquid went to Pantinople’s house to sleep on the porch. Around midnight, Pantinople was awakened by a thud and saw appellants Wilbur Aboga, Rodolfo Navarra, and “Little Boy” Navarra armed with bolos. “Little Boy” attempted to hack Pantinople, who escaped inside. Both Pantinople and his wife, Luzviminda, witnessed from close range the three accused repeatedly hacking Roquid as he lay defenseless. Roquid was pronounced dead on arrival at the hospital, with multiple hacked wounds per the autopsy report.
ISSUE
The core issue is whether the prosecution evidence, particularly the eyewitness testimonies, sufficiently establishes the guilt of appellant Wilbur Aboga for the crime of Murder beyond reasonable doubt, overcoming his defense of alibi.
RULING
The Supreme Court affirmed the conviction. The legal logic rests on the strength of positive identification and the weakness of alibi. Eyewitnesses Reynaldo Pantinople and Luzviminda Pantinople positively identified Aboga as one of the assailants. Their testimonies were deemed credible and reliable. The Court emphasized that both witnesses knew Aboga personally for a considerable time prior to the incident, making their prompt identification natural and trustworthy. Furthermore, their immediate report to authorities after the crime, while still under emotional distress, negated any possibility of fabrication. The Court found sufficient motive arising from the earlier altercation during the drinking session, where Pantinople, a companion of the victim, had assaulted co-accused Navarra.
Against this positive identification, Aboga’s defense of alibi failed. The Court reiterated the doctrine that alibi cannot prevail over the positive testimony of credible witnesses who categorically identified the accused. Moreover, for alibi to prosper, it must be demonstrated that it was physically impossible for the accused to be at the crime scene. The Court noted that the location of the crime was merely 500 meters away from Aboga’s alleged location, rendering his presence at the scene physically possible. Thus, the trial court correctly found conspiracy among the attackers, as their collective armed assault on a sleeping victim demonstrated a unity of purpose. The penalty of reclusion perpetua was sustained, with the civil indemnity increased to Thirty Thousand Pesos.