PEOPLE OF THE PHILIPPINES, vs. REYNALDO CARAIG y FELIX.
- G.R. Number: G.R. No. 91162
- Promulgated: 1991-10-03
- Ponente: Medialdea, J.
Doctrine
An alibi is a weak defense against positive identification by an eyewitness, especially when the alibi is established mainly by the accused and lacks credible corroboration.
Evident premeditation must be clearly proven; absent such proof, a killing qualified as murder must be reclassified as homicide.
Where a conviction is reduced from murder to homicide, the court must impose the proper indeterminate penalty and may adjust the civil indemnity accordingly.
Facts
Appellant Reynaldo Caraig was charged with murder for the killing of Armando Villena on 19 January 1981, in Criminal Case No. R-81-724 of the RTC, Branch 39, Manila (information alleges stabbing with intent to kill, with premeditation and treachery).
The trial court convicted appellant of murder; appellant raised alibi and other assignments of error on appeal contesting the conviction and the qualifying circumstance of evident premeditation.
The Court of Appeals (First Division) found positive eyewitness identification against the appellant and sustained conviction but modified the offense from murder to homicide for lack of proof of evident premeditation, adjusting the penalty and indemnity.
Issues
Whether the appellant's alibi can prevail against the positive eyewitness identification.
Whether evident premeditation was sufficiently proven to uphold a conviction for murder.
Whether the proper conviction, penalty, and civil indemnity should be modified given the lack of proof of evident premeditation.
Ruling
Alibi fails where positive eyewitness testimony identified the accused at the scene; alibi is weak if established mainly by the accused and not credibly corroborated.
Evident premeditation was not proven; hence the conviction for murder cannot stand and was reduced to homicide.
The judgment was modified: appellant sentenced to an indeterminate penalty of 8 years and 1 day of Prision Mayor to 14 years, 8 months and 1 day of Reclusion Temporal, ordered to indemnify heirs P50,000, and to pay costs.
Keywords
G.R. No. 91162, PEOPLE OF THE PHILIPPINES v. REYNALDO CARAIG y FELIX, crime of murder, intent to kill, evident premeditation, treachery, stabbing with a deadly weapon, mortal wounds, guilty beyond reasonable doubt, LIFE IMPRISONMENT, indemnify the heirs, Article 29 of the Revised Penal Code, Post Mortem Report, multiple stab wounds, piercing the lungs, pericardium, right heart, pulmonary artery, fatal wounds, appellant