PEOPLE OF THE PHILIPPINES vs. EDWIN BELIBET, MANNY BANOY and RONNIE ROSEROs.
- G.R. Number: G.R. No. 91260
- Promulgated: 1991-07-25
- Ponente: Regalado, J.
Doctrine
Appellate courts will not disturb a trial court's credibility findings absent plain oversight of material facts because the trial court observed witness demeanor firsthand.
Positive identification by a prosecution witness generally prevails over the accused's denial; denial and alibi are inherently weak defenses against credible positive testimony.
Alibi succeeds only if established by clear and convincing evidence showing physical impossibility of the accused's presence at the crime scene; mere assertion without such proof is insufficient.
Facts
Accused-appellants were convicted by Branch 47, Regional Trial Court of Masbate for the killing of Gracito Hatulan and appealed to the Court seeking acquittal.
The trial court found appellants guilty of murder employing superior strength qualified by treachery and sentenced each to reclusion perpetua, indemnity of P30,000, accessory penalties, and costs.
Appellants asserted alibi: that they had gone to a dancing hall and returned home by trails at times they claim made it impossible to have committed the crime.
The seashore where the killing occurred was only 50 meters from the dancing hall and some residences; the farthest appellant lived 4 kilometers away.
Issues
Whether the prosecution proved the guilt of the appellants beyond reasonable doubt.
Whether the appellants' alibi negates their criminal liability.
Ruling
The Court affirmed the conviction of appellants for murder; judgment of the trial court is affirmed with modification increasing indemnity to the heirs to P50,000, appellants solidarily liable.
Keywords
G.R. No. 91260, murder, reclusion perpetua, indemnify the heirs, accessory penalties, preventive imprisonment, treachery, evident premeditation, superiority of strength, proof beyond reasonable doubt, credibility of witnesses, inconsistencies and contradictions, leading question, quantum of evidence, felony, testimony, appellants, credibility, prosecution, witness