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A Case Brief

ANTONIO LEJANO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

G.R. No. 176389

PEOPLE OF THE PHILIPPINES, Appellee, vs. HUBERT JEFFREY P. WEBB,

ANTONIO LEJANO, MICHAEL A. GATCHALIAN, HOSPICIO FERNANDEZ,

MIGUEL RODRIGUEZ, PETER ESTRADA and GERARDO BIONG, Appellants.

G.R. No. 176864

FACTS: On June 30, 1991 Estrellita Vizconde and her daughters Carmela,

nineteen years old, and Jennifer, seven, were brutally slain at their home in

Paraaque City. Following an intense investigation, the police arrested a group of

suspects, the Barrosso group, an Akyat Bahay gang, some of whom gave

detailed confessions. But the trial court smelled a frame-up and eventually

ordered them discharged. Four years later in 1995, the National Bureau of

Investigation presented Jessica Alfaro as the state witness who described the

crime and positively identified all the suspects who committed the crime. Thedefense however, questioned the credibility of Alfaro, being a drug dependent

and being an NBI asset who is skilled to concoct information. Likewise, during

the trial, Webbs alibi appeared the strongest since he claimed that he was then

across the ocean in the United States of America. He presented the testimonies

of witnesses as well as documentary and object evidence to prove this.

The trial court rendered judgment in 1994, finding all the accused guilty as

charged. On appeal, the Court of Appeals affirmed the trial courts decision. The

appellate court did not agree that the accused were tried by publicity or that the

trial judge was biased. On motion for reconsideration by the accused, the Court

of Appeals' Special Division of five members voted three against two to deny the

motion,

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hence, the present appeal.

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ISSUE: Whether or not Webbs defense of alibi and denial can rebut Alfaros

testimony of positive identification that may lead to his acquittal.

HELD: Yes. The Supreme Court held that the defense of alibi of Webb rebuts the

testimony of positive identification of Alfaro that leads to his acquittal.

REASONS FOR DECISION: The trial courts and the Court of Appeals reason that

Webbs alibi cannot stand against Alfaros positive identification of him and thatWebbs denial and alibi were fabricated was demolished by the Supreme Court.

It ruled that not all denials and alibis should be regarded as the weakest defense

as it could be easily fabricated and difficult to disprove. Indeed, if the accused is

truly innocent, he can have no other defense but denial and alibi. The conclusion

that a positive declaration from a witness that he saw the accused commit the

crime should not automatically cancel out the accuseds claim that he did not doit. The elements to establish alibi that the accused must prove by positive, clear,

and satisfactory evidence; that he was present at another place at the time of the

perpetration of the crime; and that it was physically impossible for him to be at

the scene of the crime, were all regarded as facts and have evidentiary value that

would support for the acquittal of the accused.