G.R. Nos. 100225-26 May 11, 1993
People of the Philippines, plaintiff-appellee, vs. Raul Santos y Narciso, Mario Morales y Bacani, Peter Doe and Richard Doe, Accused, Raul Santos y Narciso, accused-appellant.

FACTS

On May 26, 1989, in Navotas, Metro Manila, Glicerio Cupcupin and Alberto Bautista were in a jeep driven by Cupcupin. At around 11:45 a.m., while the jeep was stopped at the corner of Estrella and Yangco Streets, two armed men approached and fired at them. Cupcupin sustained multiple gunshot wounds and died. Bautista was also shot but managed to escape. He identified one of the assailants as accused-appellant Raul Santos and the other as Mario Morales (still at large). Police Aide Victorino Bohol, who was directing traffic nearby, witnessed the shooting and also identified Santos as one of the gunmen. An autopsy revealed Cupcupin sustained 19 gunshot wounds. Santos was charged with murder and frustrated murder. At trial, he pleaded not guilty and interposed the defense of alibi, supported by testimonies from a friend and his sister. The trial court convicted him, sentencing him to life imprisonment for murder and an indeterminate penalty for frustrated murder, and ordering him to pay indemnity. Santos appealed, contesting the positive identification by the prosecution witnesses and arguing that the trial court erred in considering another case filed against him.

ISSUE

1. Whether the trial court erred in holding that the accused was positively identified by the prosecution witnesses and in rejecting his defense of alibi.
2. Whether the trial court erred in considering another case filed against the accused in holding him guilty.
3. Whether the trial court erred in convicting the accused.

RULING

The Supreme Court AFFIRMED the conviction with modifications. It held that the positive identification of Santos by eyewitnesses Alberto Bautista (the surviving victim) and Police Aide Victorino Bohol was credible and reliable. The conditions at the time of the crime—high visibility at near noon, good weather, and the witness’s proximity—provided ample opportunity for clear observation. The defense of alibi, being weak and uncorroborated by independent credible persons, could not prevail over the positive identification. The Court also found that the trial court did not err in its consideration of the evidence, as the reference to another case was merely part of the narrative of how the investigation led to Santos and did not affect the weight of the evidence for the crimes charged. The penalty for murder was corrected to reclusion perpetua, and the civil indemnity was increased to P50,000.00. The appealed judgment was affirmed with these modifications.