G.R. No. 130655 ; August 9, 2000
People of the Philippines, plaintiff-appellee, vs. Leo Macaliag, Jesse Torre and Juliver Chua, accused. Jesse Torre and Juliver Chua, accused-appellants.

FACTS

On the night of April 16, 1995, in Iligan City, Brian Jalani was stabbed to death. Eyewitness Anacleto Moste testified that he responded to cries for help and saw three men attacking Jalani near a creek. He positively identified the assailants as appellants Jesse Torre and Juliver Chua, along with co-accused Leo Macaliag, all of whom were personally known to him. Moste stated there was adequate lighting from a nearby lamp post, he was only 8 to 10 meters away with no obstructions, and he saw Torre holding the victim from behind while Chua and Macaliag took turns stabbing him. The victim sustained six stab wounds. The appellants fled but were eventually apprehended months later.
At trial, appellants interposed the defense of alibi. Juliver Chua claimed he was at a disco in another part of the city at the time of the crime and only learned of the killing later from his co-accused. His alibi was corroborated by his girlfriend. Jesse Torre similarly denied involvement. They argued that the prosecution failed to prove their guilt beyond reasonable doubt.

ISSUE

Whether the guilt of accused-appellants Jesse Torre and Juliver Chua for the crime of Murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Anacleto Moste to be credible, positive, and categorical. His identification of the appellants was reliable given his proximity to the crime scene, the sufficient illumination, his familiarity with the individuals involved, and the absence of any ill motive to falsely testify against them. The defense of alibi cannot prevail over such positive identification. For alibi to succeed, the accused must demonstrate not only their presence elsewhere but also the physical impossibility of being at the locus criminis. Appellants failed to establish this impossibility, as the disco they referenced was not so geographically remote as to preclude their presence at the crime scene.
The Court upheld the finding of treachery (alevosia), qualifying the killing to Murder. The attack was sudden and from behind, with the victim being restrained by one assailant while the others stabbed him, rendering him defenseless and unable to retaliate. This method ensured the execution of the crime without risk to the assailants. However, the Court modified the award of damages, increasing the civil indemnity for death to P50,000.00 and awarding an additional P50,000.00 as moral damages, in line with prevailing jurisprudence. The penalty of reclusion perpetua was affirmed.