GR L 71044; (March 1987) (Digest)
G.R. Nos. L-71044-45, March 16, 1987
People of the Philippines vs. Rodolfo de la Cruz
FACTS
Accused-appellant Rodolfo de la Cruz, along with two others identified only as “Flory” and “Jojo,” was charged with Murder for the killing of Luisito Apostol and Frustrated Murder for the stabbing of Simplicio de Castro. The incidents occurred on September 23, 1979, in Caloocan City. The prosecution evidence established that after an altercation at the Blue Heaven Restaurant where the accused worked as waiters, the victims, along with waitress Fe Ramos, left. The three accused pursued them. At a jeepney stop, the accused blocked the vehicle, forcibly pulled out the three passengers, and stabbed both Apostol and de Castro. Apostol died instantly, while de Castro survived after extensive medical treatment. The trial court acquitted de la Cruz of Frustrated Murder but convicted him of Murder, sentencing him to reclusion perpetua. His co-accused remained at large.
ISSUE
Whether the trial court erred in convicting the accused-appellant of murder based on the credibility and sufficiency of the prosecution witnesses’ testimonies.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s findings on witness credibility, emphasizing the well-settled rule that appellate courts generally accord high respect to the trial court’s factual conclusions and credibility assessments, as it had the direct opportunity to observe witness demeanor. The appellant argued that witness Fe Ramos’s testimony supported his innocence, as she stated she did not see him stab Apostol, only that he was with the assailants. However, the Court found this did not exonerate him, as Ramos corroborated that the appellant was part of the group that attacked the victims.
Crucially, the Court gave weight to the positive identification by the surviving victim, Simplicio de Castro, who testified that he saw appellant de la Cruz stab Luisito Apostol. The defense’s challenge to de Castro’s credibility—citing his initial failure to name the appellant during a hospital investigation while in serious condition—was rejected. The Court agreed with the Solicitor General that the victim’s physical state at that time could have affected his memory, and his subsequent positive courtroom identification, absent any proven ill motive, was deemed credible. The appellant’s defense of alibi, being uncorroborated, could not prevail over this positive identification. The Court thus found no error in the trial court’s judgment.