People v. De la Cruz
REITERATIONFacts
The Antecedents: On September 23, 1979, Luisito Apostol and Simplicio de Castro were at the Blue Heaven Restaurant. An altercation occurred among waitresses, and Apostol and de Castro attempted to pacify them. The accused, Rodolfo de la Cruz, along with two others identified as "Flory" and "Jojo," also waiters, were not involved in the initial quarrel but also tried to pacify the waitresses. After leaving the restaurant, Apostol, de Castro, and a waitress boarded a jeepney. The three accused pursued them, blocked the jeepney at a red signal, pulled the passengers out, and stabbed Apostol and de Castro. Apostol died instantaneously, while de Castro sustained serious physical injuries requiring surgery and hospitalization for approximately six months. The doctor testified that de Castro's injuries could have been fatal without medical intervention. Procedural History: Rodolfo de la Cruz was charged in two informations: one for Murder (of Luisito Apostol) and another for Frustrated Murder (of Simplicio de Castro). The Regional Trial Court of Caloocan City found the accused guilty of Murder and sentenced him to reclusion perpetua, to indemnify the heirs of Luisito Apostol, and to pay costs. He was acquitted of the charge of Frustrated Murder. The co-accused, "Flory" and "Jojo," remained at large. The Petition: The accused-appellant appealed the decision, assigning as errors the court's holding that the testimonies of prosecution witnesses were sufficient to attribute the killing of Luisito Apostol to him, and that a judgment of conviction was rendered despite the alleged absence of evidence.
Issue(s)
Whether the trial court erred in holding that the testimonies of prosecution witnesses Fe Ramos and Simplicio de Castro were sufficient to attribute the killing of Luisito Apostol to the accused-appellant, considering the sufficiency of evidence and credibility of witnesses. Whether the trial court erred in rendering a judgment of conviction despite the alleged absolute absence of evidence to support the same, and whether the defense of alibi was sufficiently established.
Ruling
The judgment of the Regional Trial Court finding the accused-appellant guilty of murder is AFFIRMED.
Ratio Decidendi
On the sufficiency of evidence and credibility of witnesses: The Court reiterated the well-settled rule that the findings of fact of the trial court and its conclusions regarding the credibility of witnesses are generally accorded high respect by the appellate court. While Fe Ramos testified that she did not see the appellant actually stab the victim, she corroborated the testimony of Simplicio de Castro that the appellant was one of those who ganged up on the victim. Simplicio de Castro positively identified the appellant as the one who stabbed Luisito Apostol. The Court emphasized that the testimony of a single witness, if positive and credible, is sufficient to support a conviction even in a charge for murder. The appellant's contention that de Castro could not have given an accurate account due to his own near-fatal wounds was dismissed, as de Castro was conscious and coherent at the time of his initial investigation and was able to discern events. Furthermore, de Castro's initial failure to name the assailants to Detective Lascano was explained by his serious condition at the time of the investigation, and he later positively identified the appellant in open court. The Court found no motive for de Castro to fabricate such a story, giving credence to his testimony. On the defense of alibi: The Court found the appellant's alibi, which was established only by himself, to be uncorroborated. The defense claimed he stayed behind at the restaurant, but no other employee was presented to support this. This lack of corroboration was deemed fatal to the defense, especially in light of the categorical statement of Simplicio de Castro that he saw the appellant stab Luisito Apostol. The Court reiterated the established rule that alibi cannot prevail over positive testimony.
Main Doctrine
The testimony of a single witness, if positive and credible, is sufficient to support a conviction even in a charge for murder. Alibi cannot prevail over positive testimony, especially when not corroborated.