G.R. No. L-75355 October 29, 1987
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VENANCIO ANDRES Y SEVILLA, accused-appellant.

FACTS

The case involves the killing of Armando Andaya, a Philippine Constabulary member, in the early morning of March 8, 1980, at a street corner in Tondo, Manila. The victim was hacked to death with a heavy, sharp instrument while sleeping on a table in front of a store. The prosecution’s case primarily rested on the positive identification by eyewitness Maximino Verzosa, a security guard on duty, who testified that he saw accused-appellant Venancio Andres hack the victim twice. The prosecution also presented evidence of a prior quarrel between the victim and the appellant’s father on the preceding day. The defense, however, presented an alternative narrative, claiming through witness Edgardo Cabahug that a certain “Johnny Rodel” was the actual perpetrator. The appellant also interposed an alibi, testifying that he was sleeping at his residence, which was a five-minute walk from the crime scene, at the time of the incident.

ISSUE

The core issue is whether the guilt of the accused-appellant for the crime of Murder was proven beyond reasonable doubt, considering the conflicting testimonies and his defense of alibi.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s reliance on the positive and credible testimony of eyewitness Maximino Verzosa, who consistently identified the appellant as the assailant. The legal logic is clear: positive identification, when categorical and consistent and without ill motive, prevails over a denial and alibi. The defense’s presentation of an alternative suspect, Johnny Rodel, was deemed insufficient to cast reasonable doubt, as it was uncorroborated and no evidence showed any police effort to locate or investigate this alleged perpetrator. Regarding the alibi, the Court reiterated the doctrine that it is inherently weak and cannot stand against positive identification. Crucially, the appellant himself admitted his residence was merely five minutes from the crime scene, thus failing to demonstrate the physical impossibility of his presence at the locus criminis. The killing was correctly qualified as Murder due to treachery (alevosia), as the attack was made on a sleeping and defenseless victim. The penalty was modified to an indeterminate sentence of 10 years and 1 day of prision mayor as minimum to 17 years, 4 months, and 1 day of reclusion temporal as maximum.