G.R. Nos. 73978-80 April 26, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ISAIAS GLINOGO alias “BEBOT GURANG” and RUEL RIVERA alias “RUEL AUGUIS” alias “RUEL BAGUIS”, accused. RUEL RIVERA alias “RUEL AUGUIS” alias “RUEL BAGUIS”, accused-appellant.

FACTS

Accused Ruel Rivera and Isaias Glinogo were charged with two counts of Murder for the deaths of Alberto Camasora and Armando Aguilar, and Frustrated Murder for the injuries to Baltazar Galve. The incidents occurred on the evening of January 12, 1984, at the Silway Bridge in General Santos City. The trial court, in a consolidated decision, acquitted both accused of Frustrated Murder. It also acquitted Glinogo for the murder of Camasora and Rivera for the murder of Aguilar, finding no conspiracy. However, it convicted Rivera of murdering Camasora and Glinogo of murdering Aguilar, sentencing each to reclusion perpetua. Rivera appealed, arguing his guilt was not proven beyond reasonable doubt.
The prosecution’s case rested primarily on the eyewitness account of victim Baltazar Galve. He testified that while he and his companions were on the bridge, he was stabbed by Loloy Padilla, Aguilar was stabbed by Glinogo, and Camasora was stabbed by both Padilla and Rivera. Galve positively identified Rivera, whom he knew personally, as one of Camasora’s assailants, stating the bridge was illuminated by an electric light. Medical testimony corroborated the nature of Camasora’s fatal stab wound. The defense, for its part, presented alibi. Rivera claimed he was guarding a house approximately 100 meters away at the time and only later helped transport the wounded to the hospital.

ISSUE

Whether the guilt of accused-appellant Ruel Rivera for the murder of Alberto Camasora was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed Rivera’s conviction. The Court meticulously applied the legal principles governing alibi and positive identification. For alibi to prevail, the accused must demonstrate it was physically impossible for him to be at the crime scene. The Court found Rivera’s alibi weak and unconvincing. The house where he claimed to be was merely 100 meters from the Silway Bridge, a distance that did not preclude his presence at the locus criminis. It was not impossible for him to have been at the bridge, committed the crime, and returned to the house.
Conversely, the positive identification by eyewitness Baltazar Galve was deemed clear, categorical, and credible. Galve knew Rivera prior to the incident and recognized him under the illumination of an electric light at the bridge. His testimony was straightforward, specifically narrating that Rivera stabbed Camasora in the stomach, a detail consistent with the medical findings. The Court emphasized that positive identification, when credible, prevails over a deniable alibi. The trial court’s assessment of Galve’s credibility was accorded great respect. Therefore, Rivera’s criminal liability for the murder of Alberto Camasora was established beyond a reasonable doubt. The appealed decision was affirmed with the modification of increasing the civil indemnity to P30,000.00.