People v. Suitos
REITERATIONFacts
The Antecedents: On September 5, 1987, Jesus Ylarde was shot and killed in Umingan, Pangasinan. The information accused Wilson Suitos, Vic Suitos, Boy Villar, and Alvaro Suitos @ "Barang Suitos," along with Sgt. Claro Suitos @ "Rey Suitos," of Murder with the Use of Unlicensed Firearms. The prosecution alleged that the accused conspired, confederated, and helped one another, with intent to kill, treachery, and evident premeditation, to shoot Jesus Ylarde with unlicensed firearms, inflicting fatal gunshot wounds. Procedural History: The Regional Trial Court, Branch 38, Lingayen, Pangasinan, found Alvaro Suitos guilty beyond peradventure of doubt of Murder, sentencing him to reclusion perpetua and ordering him to indemnify the heirs of the deceased. The other accused remained at large. The Petition: Accused-appellant Alvaro Suitos appealed the decision, alleging that the trial court erred in not giving credence to his defense of alibi and in finding him guilty beyond reasonable doubt of Murder.
Issue(s)
Whether the trial court erred in not giving credence to the defense of alibi raised by the accused-appellant. Whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt of the crime of Murder.
Ruling
The Supreme Court affirmed the conviction of Alvaro Suitos for Murder, subject to modifications in the indemnity awarded. The Court upheld the trial court's finding that treachery qualified the killing to Murder. The award for actual damages, death indemnity, and loss of earning capacity were modified.
Ratio Decidendi
On the issue of alibi: The defense of alibi cannot prevail over the positive eyewitness testimony of the victim's daughters, Jovy and Vivian Ylarde, who positively identified Alvaro Suitos as one of the assailants. The Court found no reason to doubt the truth and veracity of their testimonies, noting their clear and positive identification of the accused, whom they knew for a long time. Minor contradictions in their testimonies were considered natural and did not impeach their credibility. Furthermore, the accused's own testimony established that his residence was only one kilometer away from the crime scene, and it would take only about five minutes to reach the Poblacion by tricycle, negating the physical impossibility of his presence at the scene of the crime. The Court reiterated the consistent holding that alibi will not prosper where the accused is positively identified and there is no physical impossibility of his having committed the crime. On the issue of guilt for Murder: The Court found that the crime committed was Murder qualified by treachery. The victim was shot before the eyes of his daughters, who positively identified the assailants. The three men, armed with guns, took turns shooting at Jesus Ylarde. The accused Alvaro Suitos was found to have shot the victim in concert with his companions. While evident premeditation was alleged in the information, the evidence was insufficient to prove it. However, treachery was correctly appreciated. Treachery is present when the offender employs means, methods, or forms in the execution of the crime that tend directly and specially to insure its execution without risk to himself arising from the defense the offended party might make. In this case, three armed men suddenly appeared before the victim and shot him thrice in quick succession without warning, leaving him no opportunity to defend himself or retaliate. The shooting was so sudden and unexpected that the victim was in no position to defend himself. The acts of the accused and his companions were deliberately and consciously adopted, as they were all armed, surprised the victim, and fled in the same direction afterward. The conviction of the appellant was therefore upheld.
Main Doctrine
The defense of alibi cannot prevail over positive eyewitness identification of the accused, especially when the accused's presence at the scene of the crime is not physically impossible. Treachery is present when the attack is sudden and unexpected, giving the victim no opportunity to defend himself or retaliate, and such means of execution were deliberately adopted.