In Rene Soriano v. People, the Supreme Court affirmed the conviction of Rene Soriano for homicide with frustrated homicide, emphasizing that a positive identification by a credible witness outweighs the defense of alibi. The Court highlighted that for an alibi to be valid, it must not only demonstrate the accused was elsewhere but also prove it was physically impossible for them to be at the crime scene. This ruling underscores the importance of credible eyewitness testimony and the challenges defendants face when relying on alibi as a primary defense.

Can a Single Eyewitness Account Shatter an Alibi? A Look at the Soriano Case

The case revolves around the tragic events of December 29, 1994, in San Carlos City, Pangasinan. Rene Soriano was charged with the death of Ernesto Amarillo and the serious wounding of Soledad Ferrer. The prosecution’s key witness, Benjamin Cabansag, testified to seeing Soriano firing an armalite rifle, hitting Amarillo and Ferrer. Soriano, however, claimed he was at his army base in Kalinga, Apayao, at the time of the incident, presenting fellow officers to corroborate his alibi. The central legal question is whether Soriano’s alibi holds weight against the positive identification made by Cabansag.

At trial, the Regional Trial Court (RTC) found Cabansag’s testimony credible and convicted Soriano. This conviction was affirmed by the Court of Appeals (CA), leading Soriano to appeal to the Supreme Court. The Supreme Court evaluated the strength of the alibi defense presented by Soriano. An alibi is inherently a weak defense because it’s easily fabricated, and for it to succeed, the accused must prove they were elsewhere when the crime occurred and that it was impossible for them to be physically present at the crime scene. Soriano argued he was at Camp Boloan in Kalinga, Apayao. The Court determined it wasn’t impossible for Soriano to travel from Kalinga to San Carlos City in time for the shooting.

Soriano’s defense leaned heavily on the presumption of regularity of official functions, as his fellow officers testified to his presence at the camp. The Court, however, emphasized that this presumption is disputable and was overcome by Cabansag’s eyewitness account placing Soriano at the scene. The Court highlighted that, the trial court aptly noted the possibility of securing documents and testimonies from fellow soldiers to bolster the alibi, weakening its credibility. Instead the RTC decision emphasized:

As to the documents presented by the accused supporting his theory that he was in Kalinga Apayao, the Court cannot accord its reliance on the same because alibi cannot prevail over the positive identification of prosecution eyewitness. The facility which the accused can secure documents to bolster his claim that he was not present at the scene of the crime cannot be denied considering that the sources of such documents are his fellow soldiers many of whom are his subordinates.

The defense also attempted to discredit Cabansag, questioning his behavior during and after the shooting and highlighting supposed inconsistencies in his testimony. The Court of Appeals countered that people react differently to shocking events, and there’s no standard behavioral response to frightful experiences. Further undermining Soriano’s case was his seemingly indifferent reaction to his own brother’s death during the incident. The Court noted his silence and lack of pursuit of justice for his brother’s death cast doubts on his credibility and the tenability of his alibi. His lack of response was suspicious and further solidified the conviction by the RTC. Also, The Court then wrote the following:

The credibility of the accused is made suspect because the defense from their own evidence, his brother was also among the fatalities of the incident that occurred in the evening of December 29, 1994. His silence on the matter of death of his own brother is not one normally the outrage of which is to be suffered in silence, and yet, no complaint was ever filed against anybody responsible for the death of Loreto Soriano.

The Court ultimately ruled that Cabansag’s positive identification of Soriano as the shooter was credible, given he was a former neighbor and schoolmate. His testimony regarding the armalite rifle was consistent with physical evidence at the crime scene. The Court, therefore, upheld Soriano’s conviction. Furthermore, the Supreme Court also tackled the aspect of moral damages, underscoring that moral damages are due in instances of murder or homicide, acknowledging the emotional distress that families experience as a result of a brutal and tragic crime. Citing the People vs. Panado, the Court explained:

Unlike in the crime of rape, we grant moral damages in murder or homicide only when the heirs of the victim have alleged and proved mental suffering. However, as borne out by human nature and experience, a violent death invariably and necessarily brings about emotional pain and anguish on the part of the victim’s family.

Additionally, moral damages were also awarded to Soledad Ferrer, who was seriously injured in the event. This decision clarifies that an alibi can be successfully countered by a reliable witness and that not accounting for family member death would create a suspicious stance for the crime charged.

FAQs

What was the key issue in this case?	The primary issue was whether the defense of alibi presented by Rene Soriano was sufficient to overturn his conviction for homicide with frustrated homicide, given the positive identification by an eyewitness.
Why was Soriano’s alibi rejected by the court?	Soriano’s alibi was rejected because the court found it was not impossible for him to be at the crime scene, even if he was at his army base as claimed. Additionally, a credible eyewitness positively identified him as the shooter.
What is required for an alibi to be considered valid?	For an alibi to be valid, the accused must prove they were elsewhere when the crime occurred and that it was physically impossible for them to be present at the crime scene during the commission of the crime.
What role did the eyewitness testimony play in the verdict?	The eyewitness testimony of Benjamin Cabansag was crucial, as he positively identified Soriano as the shooter. The court found his testimony credible, especially since he was a former neighbor and schoolmate of Soriano.
Why didn’t the testimonies of Soriano’s fellow officers support his alibi?	The court viewed the testimonies of Soriano’s fellow officers with caution, noting they were part of a group where loyalty and obedience were highly valued, suggesting a potential bias in their statements.
What did the court say about unusual behavior during shocking events?	The court acknowledged that people react differently to shocking events, so Cabansag’s reactions during the shooting were seen as normal, so nothing questionable about it could arise. There is no expected form of behavior under startling or frightful experiences.
Why did the court question Soriano’s reaction to his brother’s death?	The court found it suspicious that Soriano did not pursue justice for his brother’s death and showed indifference when it happened during the tragic event. This cast doubts on his credibility and further justified the verdict.
What is the significance of this ruling?	This ruling highlights the importance of positive identification by credible witnesses and the challenges defendants face when relying on alibi as a primary defense, underscoring that alibi is inherently a weak defense.
Were moral damages awarded in this case?	Yes, moral damages were awarded to the heirs of Ernesto Amarillo and to Soledad Ferrer, recognizing the emotional distress caused by the violent death and serious injury, regardless of the explicit pleading or proof of emotional suffering.

The Soriano v. People case reinforces the principle that positive identification by a credible witness can outweigh an alibi defense, especially when the alibi does not establish the impossibility of the accused’s presence at the crime scene. This case also illustrates the court’s careful consideration of witness credibility and the evaluation of circumstantial factors. This can mean if an accused is found lying, all of his defense becomes potentially suspect. Finally it is interesting to note how not following up on justice of family member would look suspicious.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: RENE SORIANO @ “RENATO” vs. PEOPLE OF THE PHILIPPINES, G.R. No. 148123, June 30, 2008