G.R. No. L-74675 October 18, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JUAN REYES, accused-appellant.

FACTS

The accused, Juan Reyes, was convicted of Murder for the killing of Aramis Asuncion and sentenced to reclusion perpetua by the Regional Trial Court of Masbate. The prosecution evidence established that on the evening of December 31, 1984, during a New Year’s Eve dance at Plaza Magsaysay in Aroroy, Masbate, the victim was stabbed while urinating. Eyewitness Ely Grecia, who was approximately three meters away, positively identified accused Juan Reyes as the assailant, testifying that the area was well-lit by fluorescent lamps from the plaza. Grecia himself was superficially stabbed twice by the accused when he approached the victim. Patrolman Tagumpay Mendoza, a beat patrol member, testified to a series of altercations involving the accused at the plaza that night. Although he did not witness the stabbing, he responded to a shout, found the wounded victim, and later learned from the victim’s dying declaration, taken by PFC Pimentel, that the assailant was “Jun Reyes.”
The defense interposed alibi, claiming the accused had gone home with his mother after being pacified earlier in the evening and could not have been at the scene. The accused also challenged the credibility of prosecution witnesses, citing inconsistencies, such as Grecia’s testimony on which side of the abdomen the victim was stabbed compared to the medical certificate.

ISSUE

The core issue is whether the prosecution evidence, particularly the positive identification by an eyewitness and the dying declaration, is sufficient to sustain the conviction for Murder beyond reasonable doubt, overcoming the defense of alibi.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s findings on witness credibility, which are generally accorded great respect. The alleged inconsistency in Grecia’s testimony regarding the wound’s location was deemed minor and did not detract from his positive identification of the accused as the perpetrator. The Court emphasized that the defense of alibi is inherently weak and cannot prevail against the positive identification by a credible eyewitness. This identification was corroborated by the victim’s dying declaration, which named the accused as his assailant. The Court found the confluence of Grecia’s eyewitness account and the dying declaration to be compelling evidence of guilt.
The crime was correctly classified as Murder, qualified by treachery, as the attack was sudden and unexpected, giving the victim no opportunity to defend himself. However, applying the 1987 Constitution , which prohibits the imposition of the death penalty, the prescribed penalty for Murder is reclusion temporal in its maximum period to reclusion perpetua. Consequently, the Court modified the penalty to an indeterminate sentence of ten years and one day of prision mayor, as minimum, to eighteen years, eight months, and one day of reclusion temporal, as maximum. The award of civil indemnity and moral damages was sustained.