G.R. No. L-75880 September 27, 1988
BERNARDO M. CORDIAL, petitioner, vs. PEOPLE OF THE PHILIPPINES and INTERMEDIATE APPELLATE COURT (now Court of Appeals), respondents.

FACTS

The prosecution established that on August 23, 1981, PC members Emmanuel Romero and Nicanor Lanuza were on a jeepney in Camarines Sur. The vehicle stopped, and petitioner Bernardo Cordial, armed with a knife, boarded and stabbed Romero. Lanuza was then attacked by Cordial’s companions, sustaining multiple stab wounds and losing consciousness. Romero died on the spot from multiple gunshot and stab wounds. Lanuza survived and identified Cordial as one of the assailants. Cordial was arrested months later. During police investigation, he gave a statement but refused to sign it, later claiming the answers were supplied by Lanuza. The information filed charged Cordial with murder.
At trial, Cordial interposed the defense of alibi, testifying he was working as a truck laborer in Naga City on the date of the incident. He presented co-workers and a barangay captain to corroborate his claim of being elsewhere and to impugn Lanuza’s credibility, suggesting Lanuza had a history of fabricating charges. The trial court convicted Cordial of homicide, not murder, finding the qualifying circumstances unproven. The Intermediate Appellate Court affirmed the conviction but increased the civil indemnity.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of petitioner Bernardo Cordial for homicide based on the testimony of the lone eyewitness, Nicanor Lanuza, despite the defense of alibi and alleged inconsistencies.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court held that the positive identification by eyewitness Lanuza, who had a clear view of the petitioner during the attack, prevails over the defense of alibi. Alibi is inherently weak and must demonstrate not only that the accused was elsewhere when the crime occurred but that it was physically impossible for him to have been at the scene. Cordial’s claimed workplace in Naga City was not so geographically distant from the crime scene in San Fernando, Camarines Sur, as to preclude his presence. The testimony of a single witness, if credible and positive, is sufficient for a conviction. The Court found Lanuza’s testimony straightforward and consistent on material points, surviving rigorous cross-examination. Minor inconsistencies regarding peripheral details do not undermine credibility but may even enhance it by negating rehearsal. The trial court’s assessment of witness credibility is accorded high respect. The Court also upheld the reduction of the charge from murder to homicide, as the prosecution failed to prove the qualifying circumstances of treachery or evident premeditation. The penalty imposed and the awarded indemnity were sustained as being in accordance with law.