**Facts:**
– **June 1, 1985:** Multiple victims, including Glenn Tiempo, Alfredo Nardo, Rey Bolo, Nelson Tiempo, and Rogelio Presores, were ambushed and shot by individuals armed with high-powered firearms in Talisay, Cebu.
– **After the Incident:** Second Assistant Provincial Prosecutor Juanito M. Gabiana Sr. filed charges of murder and frustrated murder against Rolusape Sabalones, Artemio Timoteo Beronga, Teodulo Alegarbes, and Eufemio Cabanero.
– **Preliminary Investigation:** Initial charges were against “John Does,” but the identities were later replaced with the names of the apprehended accused. Alegarbes died during the trial, and Cabanero remained at large. Sabalones had jumped bail but was recaptured and pleaded not guilty.
– **RTC Conviction:** The RTC convicted Sabalones and Beronga of two counts of murder and three counts of frustrated murder, sentencing them to various terms of imprisonment.
– **Court of Appeals:** The CA affirmed the RTC Decision but modified the penalties, imposing reclusion perpetua for the murders and certifying the case to the Supreme Court.
**Issues:**
1. **Credibility of Prosecution Witnesses:** Were the evidences and witness testimonies credible and sufficient to support the convictions?
2. **Defense of Alibi and Denial:** Was the defense of alibi and the denial by the accused sufficient to raise reasonable doubt?
3. **Characterization and Penalty:** How should the crimes be characterized, and what are the appropriate penalties?
**Court’s Decision:**
1. **Credibility of Witnesses and Sufficiency of Evidence:**
– The Court upheld the trial court’s assessment, confirming that the factual findings were binding and conclusive.
– Positive identification was robustly established by survivors Edwin Santos and Rogelio Presores.
– Eyewitnesses saw the assailants during a lull in continuous firing, aided by headlights illuminating the scene.
2. **Defense of Alibi and Denial:**
– The defense of alibi was deemed insufficient as it did not establish physical impossibility for the accused to be at the crime scene.
– Alibi could not overcome the direct and positive identification by credible eyewitnesses.
3. **Characterization of the Crimes and Penalties:**
– The Supreme Court upheld the convictions for murder and frustrated murder based on the positive identification and corroborative evidence.
– Treachery was confirmed as the means of execution was deliberate, giving the victims no chance to defend themselves.
– Penalties: Reclusion perpetua for the two counts of murder and revised sentences for frustrated murder to the correct application under Article 50 of the Revised Penal Code.
**Doctrine:**
1. **Factual Determination:** The Supreme Court adheres to the findings of trial courts when supported by adequate evidence and affirmed by the Court of Appeals.
2. **Alibi v. Direct Evidence:** Alibi cannot prevail over positive identification by credible witnesses.
3. **Treachery as a Qualifying Circumstance:** Needs to be markedly shown that the method of execution deprived the victim of any defense opportunity.
**Class Notes:**
– **Elements of Alibi:** Prove presence at another location and physical impossibility to be at the crime scene.
– **Positive Identification:** Direct witness testimony outweighs a suspect’s defense of alibi.
– **Adjusted Sentences:** Reflect adherence to statutory penalties for completed and frustrated crimes.
– Violation of constitutional rights relevant only if the conviction relies on custodial investigation evidence.
– **Articles of the Revised Penal Code:**
– Art. 248 (Murder)
– Art. 50 (Frustrated Offense)
**Historical Background:**
– **Era and Context:** The case exemplifies the law enforcement and judicial measures taken during the mid-1980s in the Philippines, reflecting on the processes and judicial assessments prevalent at the time.
– **Significance:** The decision reiterates the importance of credible witness testimonies and illustrates the rigor in the appellate review process, reinforcing the rule of law and judicial consistency.
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