People v. Marfil
REITERATIONFacts
The Antecedents: On April 29, 1988, between 7:00 and 8:00 p.m., accused Godofredo Marfil, accompanied by his sons Lopito and Gomer Marfil, approached the house of Cirilo Melancio. Godofredo called for Cirilo, asking him to open the door. The Melancio family, peeping through the window, saw the accused armed with an armalite, a carbine, and an M-14 rifle. Fearing for their lives, they turned off the lights and did not open the door. The accused then walked back five meters from the house and began firing at it. As a result, four of Cirilo's children, Merlinda, Marivel, Jurry, and Jenaline, sustained fatal gunshot wounds and died instantaneously. Three other children, Joel, Marivic, and Jennifer, were also hit but survived due to timely medical intervention. The accused also fired at and killed the Melancios' pig, with Godofredo remarking it was for their funeral. Procedural History: An Information was filed charging Godofredo Marfil, Lopito Marfil, and Gomer Marfil with multiple murder and multiple frustrated murder. The Regional Trial Court (RTC), Branch 17, Kidapawan, Cotabato, convicted Godofredo Marfil of four counts of murder and three counts of frustrated murder. He was sentenced to suffer four penalties of reclusion perpetua for the murders and an indeterminate penalty for the frustrated murders, and to pay civil indemnity to the heirs of the victims. The RTC ordered the issuance of warrants of arrest for Lopito and Gomer Marfil, who were at large. The Petition: Accused-appellant Godofredo Marfil appealed the RTC decision, imputing errors to the trial court in giving full weight to the prosecution witnesses' testimonies and disregarding the defense, and in convicting him despite alleged insufficiency of evidence.
Issue(s)
Whether the defense of alibi presented by the accused-appellant is sufficient to overcome the positive identification by the prosecution witnesses. Whether the prosecution sufficiently proved the guilt of the accused-appellant beyond reasonable doubt for the crimes of multiple murder and multiple frustrated murder, considering the presence of conspiracy, treachery, and evident premeditation.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding accused-appellant Godofredo Marfil guilty beyond reasonable doubt of multiple murder and multiple frustrated murder. The Court upheld the conviction and the imposed penalties.
Ratio Decidendi
On the issue of alibi and positive identification: The Court reiterated the well-settled principle that alibi is the weakest of all defenses, being easy to contrive and difficult to disprove. This defense generally cannot prevail over the positive identification of the accused by credible witnesses. In this case, Cirilo Melancio and his children Joel and Marivic positively identified the accused-appellant Godofredo Marfil as one of the assailants. The defense of alibi offered by Godofredo Marfil, stating he was being massaged by the barangay chairman due to illness, was found to be incredible. It was not enough for him to prove he was elsewhere; he had to demonstrate that it was physically impossible for him to have been present at the crime scene. The distance between his house and the victim's house was only one kilometer, easily traversable by walking or horseback within minutes, thus rendering his alibi unsubstantiated and unavailing. The Court gave full weight to the trial court's findings regarding the credibility of the witnesses, which it will not disturb unless found to be arbitrary or if crucial facts were overlooked, misunderstood, or misapplied. On the sufficiency of evidence for multiple murder and frustrated murder: The Court found that the evidence presented by the prosecution was sufficient to establish the guilt of the accused-appellant beyond reasonable doubt. The Information alleged conspiracy, confederation, and mutual help among the accused, armed with high-powered firearms, acting with intent to kill, treachery, and evident premeditation. The factual narration detailed the manner of the attack, wherein the accused fired indiscriminately at the occupied house, resulting in the death of four children and the serious injury of three others. The injuries sustained by the victims, as described, were consistent with gunshot wounds inflicted by the firearms used. The aggravating circumstances of treachery and evident premeditation were considered. Treachery was evident in the manner the attack was executed, firing upon the house without warning, catching the occupants by surprise while they were having supper. The brightness of the moon facilitated the positive identification of the assailants. The statement made by Godofredo Marfil about the pig being for their funeral further indicated a malicious intent. The Court found no reversible error in the trial court's assessment of the evidence and its conclusion that the accused-appellant was guilty of the crimes charged.
Main Doctrine
Alibi is the weakest of all defenses and is generally rejected when the accused is positively identified by witnesses. The defense of alibi must not only show that the accused was elsewhere but also that it was physically impossible for him to have been present at the scene of the crime.