People of the Philippines vs. Benjamin Bravo
G.R. No. 185282 ; 24 September 2012
PONENTE: Perez
SUBJECTS: Arson, Circumstantial Evidence, Alibi
FACTS:
On 10 August 1989, at around 9:30PM, Mauro, the private complainant, was lying in his bed on the second floor of his house when he heard gunshots. He then heard accused calling for him to come down. When he did not come down, the accused went up the stairs and pointed the gun at him, accusing him of witchcraft and putting a curse on the accused’s father. He remained silent so the accused turned around and uttered “I will burn you all. All of you will die”. About 15 seconds thereafter, Mauro saw a big fire on the second floor coming from the room of the victims. He and his children were able to jump out the window but the victims were not. During trial, the accused raised the defense of alibi, with corroborations from numerous witnesses.
ISSUE:
- Whether or not the conviction based on circumstantial evidence is proper
- Whether or not the defense of alibi is meritorious
HELD:
- Yes, the prosecution was able to prove an unbroken chain of circumstances that point to no other than the accused himself as the arsonist. The testimony of a barangay councilman, who saw the accused running away from the burning house while carrying a long firearm in addition to the threat uttered by the accused, was among the circumstances which the court used to justify the conviction.
- No, alibi is inherently weak and unreliable in the face of positive and credible testimonies of prosecution witnesses. It becomes less plausible, especially when it is corroborated by relatives and friends who may not be impartial witnesses. Physical impossibility is essential in the defense of alibi. Physical impossibility refers to distance and the facility of access between the situs criminis and the location of the accused when the crime was committed. He must demonstrate that he was so far away and could not have been physically present at the scene of the crime and its immediate vicinity when the crime was committed.
