People v. Alcantara

G.R. No. 112858-59 (March 6, 1996)

Facts:

On February 15, 1989, at approximately 9:00 AM, Mayor Jeremias Villanueva of Amadeo, Cavite, was cleaning his car at a basketball court in front of his townhouse in Las Piñas, Metro Manila. Several individuals were present in the vicinity, including his personal security, Patrolman Virgilio Lascano, and a carpenter named Apolinario Dimaano. Suddenly, a dark blue car with four occupants arrived, and Lilibeth Malinis, the mayor's housemaid, alerted the mayor about the presence of the individuals in the car. Before the mayor could react, the occupants began firing at him. The assailants exited the vehicle and shot both Mayor Villanueva and Patrolman Lascano with M-16 and M-14 rifles. After the shooting, the assailants fled the scene in the car.

The Las Piñas police, led by P/Cpl. Leopoldo Africa, arrived shortly after the incident and conducted an investigation, collecting empty shell casings from the scene. Witnesses, including Dimaano and Malinis, initially refrained from providing statements due to shock but later identified the assailants as Ralphy Alcantara and Andres "Boy" Jose, among others.

On March 16, 1989, the National Bureau of Investigation (NBI) conducted a raid at a hideout linked to the suspects, where they recovered firearms and apprehended several individuals, including Alcantara. Witnesses later identified Alcantara as one of the gunmen and linked him to the crime through ballistic evidence.

The NBI filed charges against Alcantara, Jose, and several others for the murders of Mayor Villanueva and Patrolman Lascano. During the trial, the prosecution presented eyewitness testimonies and circumstantial evidence, while the defense argued against the credibility of the witnesses and the sufficiency of the evidence.

Legal Issues:

1. Whether the trial court erred in giving credence to the testimonies of the prosecution's eyewitnesses.
2. Whether there was sufficient evidence to establish the complicity of Andres Jose in the murders.
3. Whether the trial court's decision to convict the appellants was justified despite the acquittal of their co-accused.
4. Whether the defense of alibi presented by the appellants was credible.

Arguments:

Prosecution:

• The prosecution relied on the testimonies of eyewitnesses Apolinario Dimaano and Lilibeth Malinis, who positively identified Alcantara as one of the gunmen.
• The prosecution presented ballistic evidence linking the firearms recovered during the raid to the crime.
• Testimony from Mario Concepcion, a state witness, indicated that Jose was involved in the planning and execution of the murders.

Defense:

• The defense argued that the eyewitness testimonies were fabricated and unreliable, citing the delay in identification as a reason to discredit them.
• They contended that there was no direct evidence linking Jose to the crime and that the trial court erred in convicting him based on circumstantial evidence.
• The defense also claimed that the trial court's decision to convict was inconsistent with the acquittal of their co-accused, suggesting a lack of sufficient evidence.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's conviction of Ralphy Alcantara and Andres Jose for the murders of Mayor Villanueva and Patrolman Lascano. The court found the testimonies of Dimaano and Malinis credible, noting that their identification of Alcantara was corroborated by ballistic evidence linking his firearm to the crime. The court also highlighted that the delay in identifying the assailants was adequately explained by the circumstances surrounding the case.

Regarding Jose's involvement, the court concluded that his presence in the vehicle during the shooting and the testimonies of witnesses established his complicity in the conspiracy to commit murder. The court emphasized that conspiracy could be inferred from the conduct of the accused before, during, and after the crime.

The court rejected the defense's arguments regarding the credibility of the witnesses and the sufficiency of evidence, stating that the trial court had the discretion to accept credible portions of witness testimony while disregarding others. The court also found the alibi defense unconvincing, as it did not establish that it was physically impossible for the appellants to be at the crime scene at the time of the murders.

Significant Legal Principles Established:

• The credibility of eyewitness testimony can be upheld even with delays in identification if adequately explained.
• Conspiracy can be inferred from the actions and circumstances surrounding the accused's involvement in the crime.
• The trial court has discretion in evaluating witness credibility and can accept or reject portions of testimony based on corroborating evidence.