In People v. Mejares, the Supreme Court affirmed the conviction of Eliaquim Mejares for murder, holding that a positive identification by witnesses outweighs the defense of alibi, even in the absence of established motive. This ruling emphasizes that credible eyewitness testimony directly linking the accused to the crime is sufficient for conviction, reinforcing the principle that alibi is a weak defense, especially when not substantiated by evidence proving the impossibility of the accused being at the crime scene. The decision underscores the importance of clear and convincing eyewitness accounts in Philippine criminal law.

When a Cousin’s Testimony Silences an Alibi: Justice in Ozamiz City

The case originated from the fatal shooting of Joey Cabuguas on April 21, 1996, in Ozamiz City. Gomer Permano, the victim’s cousin, testified that he saw Eliaquim Mejares approach Joey Cabuguas and shoot him multiple times. The prosecution presented additional witnesses, including Eusebio Belegulo and Celso Balos, who corroborated Permano’s account. The medical examination confirmed that Joey Cabuguas died from multiple gunshot wounds. In response, Mejares presented an alibi, claiming he was in Manila studying at PATTS College of Aeronautics during the time of the incident. He argued that the prosecution failed to establish a motive for the killing and questioned the credibility of the witnesses. The Regional Trial Court convicted Mejares, leading to his appeal to the Supreme Court.

The Supreme Court addressed the defense of alibi, stating that it is one of the weakest defenses in criminal law. The Court reiterated the principle that for alibi to be considered, the accused must demonstrate not only that they were elsewhere when the crime occurred but also that it was physically impossible for them to have been at the crime scene.

“This Court has unfailingly upheld the doctrine that alibi and denial cannot prevail over the positive identification of the accused as the perpetrator of the crime.”

In this case, the Court found that Mejares failed to prove that it was impossible for him to be in Ozamiz City on the night of the shooting. The evidence presented did not conclusively establish his presence in Manila during that specific time, especially since the school certification only indicated enrollment for the school year 1996-1997, not his whereabouts on April 21, 1996. The Court also noted the certification was considered hearsay as the School Registrar who signed it was never presented as a witness.

The Court highlighted the significance of Gomer Permano’s testimony, noting that he positively identified Mejares as the shooter. Permano’s account was deemed credible because he was only a meter away from the incident, and the dance hall was well-lit, providing a clear view. Moreover, his relationship as a cousin of the accused bolstered the truthfulness of his testimony, as recognition was straightforward. The Court emphasized that positive identification by a credible witness generally outweighs alibi and denial. The Court stated,

“Positive identification, where categorical and consistent and without any showing of ill motive on the part of the eyewitness testifying on the matter, prevails over alibi and denial.”

Addressing the delay in Celso Balos’s testimony, the Court acknowledged that people react differently to traumatic events. Balos explained that his initial reluctance stemmed from fear of reprisal, a valid concern that did not diminish his credibility. The Court has previously recognized that there is no standard way for people to react to startling or frightful events. Delay in reporting a crime does not automatically impair a witness’s credibility if the delay is satisfactorily explained. It is also worth noting that the testimonies of Balos and Belegulo substantiated that of Permano. The consistency of their accounts, along with the medical findings, strengthened the prosecution’s case.

Regarding the absence of proven motive, the Court cited People vs. Cabodoc, stating that the prosecution is not required to prove motive when the accused has been positively identified as the perpetrator. The Court quoted that

“Well entrenched is the rule that the prosecution need not prove motive on the part of the accused when the latter has been positively identified as the author of the crime… lack of motive for committing the crime does not preclude conviction.”

Even without a clear motive, the positive identification of Mejares as the shooter was sufficient for conviction. The Court highlighted that persons have been killed or assaulted for no reason at all.

The Court determined that the crime was indeed murder, emphasizing the presence of treachery. Treachery exists when the offender employs means to ensure the execution of the crime without risk to themselves arising from the defense the offended party might make. The attack on Joey Cabuguas was sudden and unexpected, with Mejares approaching the unarmed victim from behind and shooting him in the face. The victim had no chance to defend himself, and the attack was deliberate and unexpected. This treacherous manner of attack qualified the crime as murder.

Considering that no mitigating or aggravating circumstances were present, the Court upheld the trial court’s imposition of reclusion perpetua. The Court also affirmed the award of civil indemnity of P50,000.00. The Court increased the moral damages to P50,000.00, recognizing the emotional pain and distress suffered by the victim’s family due to the violent death of their loved one. The Court emphasized that moral damages are warranted even without specific proof of emotional suffering, as such suffering is inherent in the aftermath of a violent death.

FAQs

What was the key issue in this case?	The central issue was whether the accused’s defense of alibi could outweigh the positive identification by eyewitnesses, particularly when the prosecution did not establish a clear motive for the crime. The court ultimately ruled that positive identification prevails over alibi.
What is the legal definition of alibi?	Alibi is a defense where the accused attempts to prove that they were elsewhere when the crime was committed, making it impossible for them to have participated in the act. To be credible, an alibi must demonstrate that it was physically impossible for the accused to be at the crime scene.
Why did the court dismiss the accused’s alibi?	The court dismissed the alibi because the accused failed to prove that it was physically impossible for him to be at the crime scene. The evidence presented did not conclusively establish his presence in Manila at the specific time of the shooting.
What is the significance of positive identification in criminal cases?	Positive identification by credible witnesses is a crucial piece of evidence that directly links the accused to the commission of the crime. When witnesses clearly and consistently identify the accused, their testimony can be sufficient to establish guilt beyond a reasonable doubt.
Is it always necessary for the prosecution to prove motive in a murder case?	No, the prosecution is not always required to prove motive, especially when the accused has been positively identified as the perpetrator of the crime. Lack of motive does not preclude conviction, particularly if there is sufficient evidence to establish guilt.
What is treachery, and why was it relevant in this case?	Treachery is a circumstance where the offender employs means to ensure the execution of the crime without risk to themselves arising from the defense the offended party might make. In this case, treachery was present because the accused stealthily approached the unarmed victim from behind and shot him unexpectedly.
What is the penalty for murder under Philippine law?	Under Article 248 of the Revised Penal Code, as amended by Republic Act 7659, the penalty for murder is reclusion perpetua to death. The specific penalty imposed depends on the presence of mitigating or aggravating circumstances.
What are moral damages, and why were they awarded in this case?	Moral damages are awarded to compensate for the emotional pain and suffering experienced by the victim’s family. In this case, moral damages were awarded to the heirs of the victim to recognize the emotional distress caused by the violent death of their loved one.

This case underscores the enduring principle that positive identification by credible witnesses remains a cornerstone of criminal convictions in the Philippines. While defenses like alibi are available, they must be substantiated with convincing evidence demonstrating the impossibility of the accused’s presence at the crime scene. The ruling also highlights the court’s recognition of the emotional toll on victims’ families, reflected in the award of moral damages.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People vs. Mejares, G.R. No. 140204, August 15, 2002