G.R. No. L-75074 September 15, 1986
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. OSCAR OCAYA, accused-appellant.

FACTS

The case originated from the Regional Trial Court of Oroquieta City, which convicted accused-appellant Oscar Ocaya of Murder for the killing of Mario Origines. The trial court imposed an indeterminate penalty. On appeal, the then Intermediate Appellate Court affirmed the conviction but modified the penalty to reclusion perpetua, holding the Indeterminate Sentence Law inapplicable. As the modified penalty was reclusion perpetua, the Appellate Court certified the case to the Supreme Court for final determination, as required by the rules.
The prosecution evidence established that on the evening of March 7, 1982, in Aloran, Misamis Occidental, a man called for the homeowner, Bonifacia Varquez, claiming a relative had met an accident. When Mario Origines opened the door, he was suddenly stabbed by a man wearing a raincoat with a hood. During the struggle, the hood was pulled down, and eyewitnesses Julita Bulaga and German Origines, Jr., positively identified the assailant as Oscar Ocaya. The victim died from multiple stab wounds. The defense interposed alibi, claiming Ocaya was elsewhere, and questioned the witnesses’ credibility because they did not immediately name him to the police.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of Oscar Ocaya for Murder and properly modified the penalty to reclusion perpetua.

RULING

The Supreme Court affirmed the judgment of conviction and the penalty of reclusion perpetua. The Court upheld the factual findings and credibility assessments of the lower courts. It ruled that the positive identification by eyewitnesses Julita Bulaga and German Origines, Jr., who knew the appellant personally and saw his face clearly when the hood fell during the struggle, was credible and conclusive. Their initial failure to name the appellant to the police immediately after the incident was adequately explained by their state of shock and fear for their lives, as the appellant was still at large. The Court emphasized that delay in accusation, when reasonably explained, does not impair a witness’s credibility.
Regarding the penalty, the Court agreed with the Appellate Court’s modification. Murder under Article 248 of the Revised Penal Code is punishable by reclusion temporal in its maximum period to death. With no aggravating or mitigating circumstances attending the crime, the penalty should be imposed in its medium period, which is reclusion perpetua. Consequently, the Indeterminate Sentence Law is not applicable to penalties with a fixed duration like reclusion perpetua. The Court thus affirmed the penalty of reclusion perpetua, along with the awards of civil indemnity and actual damages. The defense of alibi was correctly rejected for failure to prove physical impossibility of being at the crime scene and for being inferior to positive identification.