People v. Gomez
REITERATIONFacts
The Antecedents: On March 22, 1993, in Valderrama, Antique, Jesus Sidayon was stabbed and killed. The Information alleged that the accused, Virgilio Gomez, armed with a knife, with intent to kill, treachery, and cruelty, attacked and stabbed Sidayon, inflicting a fatal wound. The trial court convicted Gomez of murder, qualified by treachery, but ruled out cruelty for lack of substantiation. The court imposed the penalty of reclusion perpetua and ordered payment of actual and civil damages. Procedural History: The trial court relied on the testimony of the lone eyewitness, Romulo Roquero, who testified that the accused stabbed the victim while the latter was about to take a drink. The defense presented an alibi, claiming the accused was in Iloilo City at the time of the incident. The trial court found the alibi unconvincing, noting that it was not physically impossible for the accused to be at the scene of the crime, given the travel time between Iloilo City and Valderrama, Antique. The court also found the eyewitness account credible and consistent with the medico-legal findings. The Petition: Accused-appellant Gomez appealed, arguing that it was physically impossible for him to be at the scene of the crime, that the eyewitness had an ill motive, and that the prosecution erred in presenting only one eyewitness. The Supreme Court reviewed these arguments.
Issue(s)
Whether it was physically impossible for the accused-appellant to have been at the scene of the crime. Whether the eyewitness Romulo Roquero had an ill motive. Whether the prosecution erred in presenting only one eyewitness. Whether treachery attended the killing of Jesus Sidayon.
Ruling
The Supreme Court affirmed the decision of the trial court, finding accused-appellant Virgilio Gomez guilty of murder and sentencing him to reclusion perpetua. The Court also affirmed the awards for actual damages and civil indemnity.
Ratio Decidendi
On the physical impossibility of the alibi: The Court held that the defense of alibi requires proof of physical impossibility to be at the scene of the crime, which must be established during the trial. The accused-appellant's argument that it was physically impossible due to travel time was raised for the first time on appeal and was not supported by evidence adduced during the trial. The Court emphasized that alibi is an inherently weak defense that must be proven with clear and convincing evidence, including proof of accessibility between the two locations. The defense failed to discharge this burden by not presenting evidence of average travel time during the trial. On the alleged ill motive of the eyewitness: The Court found the imputation of ill motive against Romulo Roquero to be unsubstantiated. There was no showing that this matter was raised during the trial, despite the opportunity for the defense to cross-examine the witness or present rebuttal evidence. In the absence of evidence of improper motive, the presumption is that the witness testified truthfully and his testimony is entitled to full faith and credit. On the presentation of a single eyewitness: The Court reiterated that the prosecution has the discretion to choose its witnesses. The presentation of a single eyewitness is not inherently dubious, as numerous convictions have prospered based on the credible testimony of one witness. The prosecution's decision not to present another witness due to his unavailability in the province was a reasonable exercise of discretion, and there was no indication of suppressed evidence. On the attendance of treachery: The Court found that treachery attended the killing. The requisites for treachery were met: the attack was executed in a manner that gave the victim no opportunity to defend himself, and this means of execution was deliberately adopted. The victim was seated and about to take a drink when the accused entered and stabbed him without warning. The attack was calculated to ensure the infliction of a fatal wound without risk to the offender, as evidenced by the nature and force of the stab wound described by the eyewitness and the medico-legal officer.
Main Doctrine
The defense of alibi requires not only proof of the accused's presence elsewhere but also proof of the physical impossibility of his presence at the scene of the crime, which must be established during the trial and not for the first time on appeal. The prosecution is not mandated to present all possible witnesses, and the testimony of a single credible eyewitness is sufficient for conviction.