People v. Pigon
REITERATIONFacts
The Antecedents: The accused-appellant, Bonifacio Pigon, was charged with robbery with homicide for the killing of Leonito Samson on December 29, 1983. The Information alleged that Pigon, with intent to kill, stabbed Samson with a fan knife known as a "flamingo," and with intent to gain, took the victim's money, shoes, pants, and T-shirt, valued at P1,500.00. Procedural History: The Regional Trial Court, Branch 49, Cataingan, Masbate, found Bonifacio Pigon guilty beyond reasonable doubt of robbery with homicide and sentenced him to reclusion perpetua. The court also ordered him to indemnify the heirs of Leonito Samson in the amount of P30,000.00. The Petition: Pigon appealed the decision, alleging that the trial court erred in convicting him despite the alleged unreliability of the prosecution's star witness, Jaime Deogrades, and in convicting him when his guilt had not been proven beyond reasonable doubt.
Issue(s)
Whether the trial court erred in convicting the accused-appellant despite the alleged unreliability of the prosecution's star witness. Whether the guilt of the accused-appellant for robbery with homicide was proven beyond reasonable doubt.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the accused-appellant Bonifacio Pigon guilty beyond reasonable doubt of robbery with homicide, and sentencing him to reclusion perpetua and to pay an indemnity of P30,000.00 to the heirs of Leonito Samson.
Ratio Decidendi
On the alleged unreliability of the prosecution's star witness: The Court found the testimony of Jaime Deogrades, a 14-year-old first cousin of the accused, to be credible. The trial court was impressed by Deogrades' demeanor, clear, spontaneous, natural, and straightforward manner of testifying, and his unshaken version of the incident despite defense attempts to discredit him. The Court found it difficult to believe that Jaime would falsely accuse his first cousin of such grave crimes simply to get even for a past slapping incident, especially given their close familial relationship. Furthermore, Jaime's passivity during the commission of the crime was reasonably ascribed to shock or fear, considering the suddenness and brutality of the assault. The Court also noted that Jaime's thumbmark on his affidavit, equivalent to a signature, and the substantial consistency between his affidavit and trial testimony lent credibility to his account. The defense's claim that Jaime was a "paid witness" was unsubstantiated, with Jaime only admitting to receiving transportation money for court appearances. On whether the guilt of the accused-appellant for robbery with homicide was proven beyond reasonable doubt: The Court found that the prosecution had sufficiently proven the guilt of the accused beyond reasonable doubt. The eyewitness testimony of Jaime Deogrades positively identified Bonifacio Pigon as the perpetrator of the crime. The Court reiterated the doctrine that proof of motive is unnecessary for conviction when the perpetrator has been positively identified by an eyewitness. The defense of alibi presented by the appellant, corroborated by Pedro Yanson, was rejected. The Court held that for alibi to succeed, it must be shown not only that the accused was at another place but that it was physically impossible for him to have been at the situs of the crime. In this case, the distance between San Rafael and Galutan was not so great as to render Pigon's presence at the crime scene impossible, especially since both barangays were within the same municipality and accessible by motorized vehicles. Moreover, alibi cannot prevail against positive identification by a credible eyewitness, which was established through Jaime Deogrades' testimony.
Main Doctrine
The defense of alibi must be substantiated by evidence that it was physically impossible for the accused to be at the situs of the crime at the time of its commission. Furthermore, alibi cannot prevail over positive identification of the accused by a credible eyewitness.