G.R. No. L-32912 October 29, 1976
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SALUSTIANO ROXAS Y SONER, defendant-appellant.

FACTS

The victim, Antero Guerra, was shot from behind and killed while walking home from a basketball game on the evening of June 21, 1969, in Ibaan, Batangas. The autopsy revealed two fatal gunshot wounds to the back, with powder burns indicating the assailant fired at close range. Prosecution witnesses Victorino and Paterno Guerra, nephews of the deceased, positively identified the appellant, Salustiano Roxas, as the gunman. They testified that Roxas, who was the conductor of a jeepney owned by Rodolfo Guerra, had earlier demanded payment of a P150.00 rental debt from the victim. Paterno specifically heard Roxas tell the victim to “pay your indebtedness… now or something will happen” moments before the shooting.
The defense presented an alibi, claiming appellant was at home, three kilometers away, at the time of the crime. Appellant denied the accusations and suggested the witnesses were motivated by a family grudge. The trial court convicted appellant of Murder qualified by treachery and sentenced him to reclusion perpetua.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellant beyond reasonable doubt, particularly in overcoming his defense of alibi.

RULING

The Supreme Court affirmed the conviction. The legal logic rests on the strength of positive identification over an uncorroborated alibi. The Court found the testimonies of the two eyewitnesses credible and consistent. They had no improper motive to falsely accuse the appellant, and their narration of the events, including the antecedent demand for payment, was natural and convincing. The defense failed to substantiate any ill motive on their part. In contrast, the defense of alibi is inherently weak and easily fabricated. For it to prevail, it must be physically impossible for the accused to have been at the crime scene. Here, it was not impossible, as appellant lived only three kilometers away, a distance he could have traversed. The alibi also lacked credible corroboration. Furthermore, the established motive—the victim’s unpaid debt concerning the jeepney which provided appellant’s livelihood—gave appellant reason to act. The manner of attack, a sudden shooting from behind while the victim was carrying trophies and unable to defend himself, clearly constituted treachery (alevosia), qualifying the killing as Murder. The trial court’s assessment of witness credibility is accorded great respect, and finding no error, the Supreme Court upheld the judgment.