### Facts:
– **Initial Incident (April 16, 1995):**
– Brian Jalani was assaulted near Baslayan Creek, Iligan City.
– Eyewitness Anacleto Moste witnessed the event and identified Leo Macaliag, Jesse Torre, and Juliver Chua as the attackers.
– Moste saw Torre holding Jalani while Chua and Macaliag took turns stabbing him.
– **Immediate Aftermath:**
– Moste and others took Jalani to Dr. Uy Hospital where he died.
– **Police Investigation:**
– Dr. Livey Villarin confirmed multiple stab wounds.
– SPO4 Antonio Lubang received a report from Moste about the incident.
– **Arrests and Proceedings:**
– Arrest of Juliver Chua (Feb 1, 1996), followed by the arrests of Macaliag and Torre (June 1996).
– During arraignment, all accused pleaded not guilty.
– Defendants presented alibis: Chua at a disco, Torre at home with fever, and Macaliag drinking at home.
– **Prosecution vs Defense:**
– Prosecution relied on Moste’s testimony and medical evidence.
– Defense claimed weak witness testimony and robust alibi.
### Issues:
1. **Credibility of the Eyewitness:**
– Was Moste’s testimony credible despite defense allegations?
2. **Sufficiency of Evidence:**
– Did the prosecution prove guilt beyond reasonable doubt?
3. **Appropriate Charge:**
– Whether the judgment for murder was correct or if it should have been for a lesser offense like homicide.
### Court’s Decision:
1. **Credibility of Eyewitness:**
– **Issue:** Defense claimed Moste’s testimony was not credible, questioning his bravery and the feasibility of his observations.
– **Resolution:** Court found Moste credible, citing his past experience and the veracity of direct observation.
2. **Sufficiency of Evidence:**
– **Issue:** Defense argued that prosecution failed to establish guilt beyond reasonable doubt and overestimated Moste’s testimony.
– **Resolution:** Court found Moste’s consistent, straightforward testimony compelling. Defendants’ alibis were deemed self-serving without credible, disinterested witnesses.
3. **Appropriate Charge:**
– **Issue:** Whether the trial court erred in convicting for murder based on treachery and evident premeditation.
– **Resolution:** Supreme Court adjusted conviction from murder to homicide but highlighted aggravating circumstance of abuse of superior strength.
### Doctrine:
– **Treachery:** Must be proven clearly and cannot be presumed. Eyewitness inability to detail attack’s commencement removes basis for treachery.
– **Eyewitness Testimony:** A single credible witness’s positive identification outweighs weak alibi defenses, especially family or friend-supported alibis.
– **Aggravating Circumstances:** Abuse of superior strength applied when multiple attackers overpower a lone, defenseless victim.
### Class Notes:
– **Key Elements of Homicide (Article 249 of Revised Penal Code):**
– **Unlawful killing without qualifying circumstances of murder.**
– **Aggravating Circumstance:** Superior strength as guiding principle.
– **Principles:**
– **Eyewitness Testimony:** Quality over quantity.
– **Alibi Defense:** Weak compared to direct identification unless backed by disinterested testimonies.
– **Statutory References:**
– **Article 248 (Murder) and Article 249 (Homicide) of the Revised Penal Code.**
– **Credibility of Witness Principles:** People v. Ganan Jr., People v. Frago, People v. Dismuke, etc.
### Historical Background:
– **Legal Context:**
– Importance of scrutinizing judicial reliability on eyewitness identifications versus alibi defenses.
– **Broader Context:**
– This case highlights the Philippine judicial system’s handling of credibility issues and detailed judicial reasoning in capital offense cases.
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