People v. De Guzman
REITERATIONFacts
The Antecedents: Accused-appellant Rizalito de Guzman, along with others, was charged with murder for allegedly conspiring and confederating to kill Carlito Mendoza y Umel on January 1, 1988, in Pasay City. The information alleged that the victim was stabbed, hacked, and hit with knives, a "gulok," and pipes, inflicting mortal wounds that caused his death. The victim was on his way to his mother-in-law's house when a group of armed men blocked their path. The victim and his companions ran for cover but were chased into an alley where the victim was attacked and stabbed by Rizalito de Guzman, Ysmael Sembrero, and Virgilio Pupulangas. The victim died upon arrival at the hospital, sustaining fourteen stab wounds. Procedural History: The Regional Trial Court (RTC) convicted Rizalito de Guzman, Arturo de Guzman, and Ysmael Sembrero of murder, sentencing them to suffer the penalty of prision mayor in its maximum period to reclusion temporal in its medium period, applying the Indeterminate Sentence Law. Arturo de Guzman and Ysmael Sembrero jumped bail and were tried in absentia. Upon appeal, the Court of Appeals (CA) found the appellant guilty beyond reasonable doubt of murder, punishable by reclusion perpetua, but certified the case to the Supreme Court for review due to its pronouncement in People v. Centeno. The Petition: The accused-appellant Rizalito de Guzman assigned errors concerning the trial court's reliance on the prosecution's theory and its failure to acquit him due to insufficient proof beyond reasonable doubt. He also interposed the defense of alibi, claiming he was in Imus, Cavite, from December 31, 1987, to January 26, 1987.
Issue(s)
Whether the prosecution sufficiently proved the guilt of the accused-appellant beyond reasonable doubt, and whether the defense of alibi is tenable. Whether the penalty imposed by the trial court was correct. Whether the award of indemnity should be adjusted.
Ruling
The Supreme Court affirmed the judgment of the Court of Appeals finding the appellant guilty beyond reasonable doubt of the crime of murder, punishable by reclusion perpetua, with a modification regarding the indemnity awarded.
Ratio Decidendi
On the sufficiency of proof, the defense of alibi, and positive identification: The Court found that the prosecution had sufficiently discharged its duty in establishing the guilt of the accused beyond reasonable doubt. While acknowledging that alibi is a weak defense, it is not always false, especially when the prosecution's evidence is weak. However, in this case, the prosecution's evidence was found to be sufficient. The alleged inconsistencies in the testimonies of prosecution witnesses Cora Limson Mendoza and Ederlin Mendoza regarding the stone-throwing incident were deemed insignificant and inconsequential, as both witnesses agreed on the essential point that the appellant was one of the attackers. Furthermore, for alibi to prosper, it must not only be shown that the accused was elsewhere but also that it was physically impossible for him to be at the scene of the crime. The Court found that the travel time between Pasay City and Imus, Cavite, was only 30-45 minutes by bus, making it not physically impossible for the appellant to have been at the situs of the crime. The defense of alibi crumbles in the face of positive identification, and the appellant was positively identified by prosecution witness Cora Mendoza as the one who first stabbed the deceased from behind. It has been consistently ruled that alibi cannot prevail over positive identification. On the penalty imposed: The Court found no error committed by the Court of Appeals in imposing the penalty of reclusion perpetua. Murder is punishable by reclusion temporal in its maximum period to death under Article 248 of the Revised Penal Code. With three distinct penalties available and no aggravating or mitigating circumstances present, the penalty imposable should be in its medium period, which is reclusion perpetua, as per Article 64(1) of the RPC. The death penalty could not be imposed under the 1987 Constitution. On the award of indemnity: The award of P30,000.00 as indemnity was increased to P50,000.00, conforming to prevailing jurisprudence.
Main Doctrine
Alibi cannot prevail over positive identification of the accused. The defense of alibi requires not only proof of presence elsewhere but also physical impossibility of being at the scene of the crime. The penalty for murder, in the absence of aggravating or mitigating circumstances, should be in its medium period, which is reclusion perpetua.