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People v De Leon (1995)

General Concepts

Davide, Jr., J.

FACTS:

 Several witnesses allegedly witnessed the accused Eleuterio de Leon gun down Marcelino Santiago, one of
the managers of Robal Transit, while the latter was driving his jeep near the bus terminal.
 One witness claimed that Santiago’s jeep had already passed him when the shots were fired. The witness
turned around to see De Leon shooting the victim with an Armalite.
 Another witness was on the street was only six meters from the accused when the shooting occurred. He
went inside the bus terminal out of fear and back outside to assist in carrying the body.
 The accused merely interposed alibi as his defense, declaring that he was waiting for his salary to be paid
on the morning of the crime.
 De Leon: Mariano (one of the witnesses) who testified, should not be given credence because he himself
was accused of having killed somebody.
 RTC: convicted De Leon and his co-accused of the crime of murder; declared the alibi offered to be feeble.

ISSUE/S:

 WoN the RTC erred in giving weight to the prosecution’s evidence and rejecting the defense of alibi: NO
o Alibi is the weakest of all defenses, for it is easy to fabricate and difficult to prove; it cannot prevail
over the positive identification of the accused by the witnesses. Moreover, for the defense of alibi to
prosper, the requirements of time and place must be strictly met.
o It is not enough to prove that the accused was somewhere else when the crime was committed, but
he must also demonstrate by clear and convincing evidence that it was physically impossible for
him to have been at the scene of the crime at the time the same was committed.
o In the instant case, such physical impossibility was not shown to have existed. By the appellant's
own admission, the place where he claimed to be was only about eight kilometers away from the
scene of the crime and that it would have taken only half an hour to traverse the distance by bus or
passenger jeep. Such distance was not so great as to preclude his having been at the scene of the
crime when the shooting occurred.
 WoN inconsistencies om the testimony of the prosecution witnesses with respect to minor details affect the
substance of their declaration: NO
o Inconsistencies reinforce rather than weaken their credibility since it is a usual occurrence that
witnesses to a stirring event would see things differently about such a startling experience.
 WoN Mariano’s testimony should be given credence: YES
o Section 20, Rule 130 of the Rules of Court provides that except as provided for in the succeeding
sections, all persons who can perceive, and perceiving, can make known their perception to others,
may be witnesses.
o Religious or political belief, interest in the outcome of the case, or conviction of a crime unless
otherwise provided by law, shall not be a ground for disqualification.
o Clearly, the mere pendency of a criminal case against a person does not disqualify him from
becoming a witness. As a matter of fact, conviction of a crime does not disqualify such person from
being presented as a witness unless otherwise provided by law.

HELD: Decision appealed from AFFIRMED.