THE PEOPLE OF THE PHILIPPINES, vs. . NORBERTO VILLAGRACIA, ELMER PAGLINAWAN, ALFONSO PASTORAL, NELSON LEDESMA, WILFREDO MANZA, NIXON LEDESMA, JOHN DOE, PETER DOE, ALEX DOE and RAMON DOEs.
- G.R. Number: G.R. No. 94471
- Promulgated: 1993-03-01
Doctrine
An alibi cannot prevail over positive eyewitness identification when the latter is supported by affirmative evidence.
In conspiracy cases, it is not necessary to show who inflicted the fatal blow; proof of conspiracy and participation suffices to sustain conviction.
Absence of ill-will or ulterior motive to fabricate strengthens the credibility of prosecution witnesses; trivial inconsistencies do not automatically impair testimony.
Facts
Three prosecution eyewitnesses positively identified the accused-appellants as the perpetrators, establishing the factum probandum for the crime.
Accused-appellants raised alibi and challenged identifications; they also argued alleged inconsistencies among witness statements and claimed forced confessions were inadmissible.
Prosecution witnesses had no shown ulterior motive to falsely implicate the accused; the Court found absence of ill-will undermines the defense theory of fabrication.
Court found any apparent inconsistencies (e.g., who inflicted the fatal blow) immaterial in conspiracy; minor infirmities in testimony were too petty to impair credibility.
Issues
Whether the positive identifications by eyewitnesses, supported by affirmative evidence, overcome the accused-appellants' alibi and other defenses.
Whether alleged inconsistencies among witnesses and claims of inadmissible forced confessions sufficiently undermine the prosecution's case.
Ruling
Yes. The Court held the three eyewitnesses' positive identifications, supported by affirmative evidence, established the factum probandum and prevail over the alibi defense.
No. The Court found no significant inconsistencies nor ulterior motive to fabricate; alleged infirmities were petty and inadmissibility of forced confessions did not negate the witnesses' open-court declarations.
Disposition: The appeal is dismissed for lack of merit and the decision of the court a quo is affirmed in toto.
Keywords
G.R. No. 94471, REMEDIAL LAW, EVIDENCE, ALIBI, positive identification, People v. Escamillas, 208 SCRA 441 [1992], People v. Francisco, 182 SCRA 305 [1990], People v. Solis, 182 SCRA 182 [1990], People v. Cruz, 208 SCRA 326 [1992], CREDIBILITY OF PROSECUTION WITNESSES, Galan v. Napase, 208 SCRA 1 [1992], People v. Mendoza, 121 SCRA 149 [1983], CRIMINAL LAW, CONSPIRACY, guilt imputable to all in equal degree, People v. Salcedo, 172 SCRA 78 [1989], People v. Macalino, 177 SCRA 185 [1989], TESTIMONIES, credibility not impaired by minor inconsistencies, People v. Collantes, 208 SCRA 853 [1992]