People v. De Guzman
REITERATIONFacts
The Antecedents: On March 15, 1997, at around 11:00 PM, William Estrella y Kliatchko and his brothers Herminio Jr. and Leander, along with others, were drinking beer in front of Alicia Store. A scooter driven by Jasper Desiderio arrived, and the passenger, appellant John Kenneth de Guzman, armed with a pistol, fired six shots at the group. William, whose back was facing the road, was hit on the upper left shoulder and later died. Julius Silva, who was with the group earlier, met the scooter carrying the appellant and Desiderio after hearing the gunshots. Herminio Jr. informed their father, who called the police. PO1 Filemon Tomas responded, recovered a slug, and accompanied the Estrellas to the hospital. William was transferred to different hospitals due to his injuries and eventually expired. Procedural History: The Regional Trial Court of Malolos, Bulacan, found appellant John Kenneth de Guzman guilty of murder and sentenced him to reclusion perpetua. The court ordered him to indemnify the heirs of the victim in the amount of P75,000.00 as actual damages. The Petition: Appellant John Kenneth de Guzman appealed the RTC decision, alleging that the prosecution evidence did not overcome his presumption of innocence and that the trial court erred in rejecting his alibi, which he claimed was corroborated by disinterested witnesses.
Issue(s)
Whether the prosecution evidence was sufficient to overcome the presumption of innocence of the accused. Whether the trial court erred in rejecting the defense of alibi.
Ruling
The appeal is bereft of merit. The assailed Decision of the trial court is AFFIRMED, with the modification that the award of actual damages is DELETED and appellant is ordered to pay the heirs of the victim P50,000 as indemnity ex delicto.
Ratio Decidendi
On the sufficiency of prosecution evidence: The Court reiterated that findings of the trial court on the credibility of witnesses are entitled to the highest degree of respect and will not be disturbed on appeal absent clear errors. Both eyewitnesses positively identified appellant as the shooter. Their testimonies were bolstered by the fact that they immediately informed their father of the incident, identifying appellant as the perpetrator. The Court found no reason to doubt their identification, considering they were acquaintances and longtime neighbors of appellant, and the conditions of visibility at the time were favorable. The fact that the witnesses are brothers of the victim does not diminish their credibility. The defense's witnesses were found to be unreliable. Therefore, the identity of the perpetrator was sufficiently established beyond reasonable doubt. On the defense of alibi: The Court found appellant's alibi unmeritorious. To successfully claim alibi, it must be physically impossible for the accused to be at the scene of the crime. Appellant failed to establish this impossibility, as his home was in the same town where the shooting occurred. Furthermore, his wife's testimony was deemed unreliable. The Court reiterated that alibi is the weakest of all defenses and cannot overcome positive identification by credible eyewitnesses, especially when it is not substantiated by clear and convincing evidence. The defense witnesses who claimed not to have seen appellant on the scooter were found to be unreliable, and their testimonies did not provide clear and convincing evidence to support the alibi.
Main Doctrine
The positive identification of the accused by credible eyewitnesses prevails over the defense of alibi, especially when the eyewitnesses are relatives of the victim, as it would be unnatural for them to accuse someone other than the real culprit. The qualifying circumstance of treachery attended the killing, as the victim was attacked suddenly and without provocation while on board a moving scooter, affording him no opportunity for retaliation.