In *People v. Alabado*, the Supreme Court affirmed the conviction of Randy Alabado for murder and frustrated murder, emphasizing the importance of positive identification by witnesses and the presence of treachery in the commission of the crimes. The court underscored that when witnesses, especially those close to the accused, positively identify the perpetrator and no ill motive is proven, their testimonies hold significant weight, reinforcing the conviction. This ruling serves as a reminder of the grave consequences of violent acts and the critical role of credible eyewitness testimony in Philippine criminal law.

A Deadly Birthday: How Positive Identification Sealed a Murderer’s Fate

The case revolves around the events of May 10, 2000, during a birthday celebration. Randy Alabado, a boarder in the Ampaya family’s home, was initially among the guests. Later that night, Ricardo Ampaya was fatally stabbed, and his daughter Evelyn Ampaya suffered multiple stab wounds. Alabado was charged with murder and frustrated murder. The trial court found him guilty, a decision affirmed by the Court of Appeals. The central question before the Supreme Court was whether Alabado was sufficiently and positively identified as the perpetrator of these crimes.

The prosecution’s case hinged on the testimonies of several witnesses, most notably Evelyn Ampaya, the victim of the frustrated murder charge. Evelyn recounted waking up to find Alabado in her room, armed with a knife. She testified that he attacked her and her father, Ricardo, who was killed during the incident. The prosecution also presented medical evidence detailing the extent of Evelyn’s injuries and the cause of Ricardo’s death. Edgar Ampaya, another sibling, testified that he witnessed Alabado stabbing their father and wrestled with him for the knife. These testimonies formed the backbone of the prosecution’s argument that Alabado was indeed the perpetrator.

Alabado’s defense rested on denial and an alibi, claiming he was intoxicated and lost consciousness after being hit on the head. He argued that the lighting conditions in Evelyn’s room were insufficient for her to positively identify him. Additionally, he questioned the reliability of Evelyn’s testimony, given her injuries and the chaos of the situation. However, the Court found these arguments unconvincing. The Court emphasized that the identity of the accused is the first duty of the prosecution, citing *People v. Delmendo*. The court stated, “It has been said that the identity of the accused is the first duty of the prosecution.”

The Supreme Court gave significant weight to the fact that Evelyn was well-acquainted with Alabado, who had been the Ampayas’ boarder for six years and was the brother of Evelyn’s fiancé. This familiarity made her identification of him more credible. Citing *People v. Hilario*, the Court noted that a witness’s long-standing acquaintance with the accused strengthens the reliability of their identification. “The fact that the witness had known the accused for five years, and was his neighbor in the community, makes them well acquainted with each other as to render credible the positive identification by the witness of the accused as the perpetrator of the offense,” the court stated.

The Court also addressed Alabado’s claim of intoxication. The Court rejected intoxication as a mitigating circumstance. It pointed out that Alabado’s defense of being unconscious was inconsistent with a claim of intoxication, as he never claimed to have become unconscious due to intoxication. “Intoxication or drunkenness is mitigating if not habitual nor intentional, and it must be indubitably proved (Art. 15, Revised Penal Code; *People v. Camano*). Accused-appellant is not entitled to the mitigating circumstance of intoxication merely on the declaration of the prosecution witness that appellant was drunk,” the court cited.

Another critical aspect of the case was the presence of treachery. The Court affirmed that the attack on the victims, who had just been awakened from sleep, was indicative of treachery. Treachery exists when the offender commits any of the crimes against persons, employing means, methods, or forms in the execution thereof which tend directly and specially ensure its execution, without risk to himself arising from the defense which the offended party might make, according to *People v. Abolidor*. The court emphasized that the victims were in no position to defend themselves against the sudden and unexpected attack.

The Court further stated that positive testimony prevails over the defense of alibi. The court emphasized that denials and alibis, unsubstantiated by clear and convincing evidence, are negative and self-serving, deserving no weight in law. The testimonies of the prosecution witnesses, who positively identified Alabado, were given more credence.

In summary, the Supreme Court upheld the lower courts’ decisions, finding Alabado guilty beyond reasonable doubt of murder and frustrated murder. The Court’s decision underscores the importance of credible eyewitness testimony, especially from individuals familiar with the accused. It also reaffirms the presence of treachery in attacks on unsuspecting victims, ensuring justice for the Ampaya family.

FAQs

What was the key issue in this case?	The key issue was whether Randy Alabado was sufficiently and positively identified as the perpetrator of the murder of Ricardo Ampaya and the frustrated murder of Evelyn Ampaya. The court focused on the credibility of the eyewitness testimonies and the presence of treachery in the commission of the crimes.
Why was Evelyn Ampaya’s testimony considered crucial?	Evelyn Ampaya’s testimony was crucial because she was a direct victim of the attack and had known Randy Alabado for six years as her family’s boarder and as the brother of her fiancé. This familiarity made her identification of Alabado more credible and reliable in the eyes of the court.
What is the legal significance of “treachery” in this case?	Treachery is a qualifying circumstance that elevates the crime to murder. In this case, the attack on the victims while they were asleep or had just awakened was considered treacherous because they were unable to defend themselves.
How did the court address Alabado’s defense of intoxication?	The court dismissed Alabado’s defense of intoxication, noting that he had not proven it to be unintentional or habitual. Furthermore, his claim of being unconscious was inconsistent with a claim of intoxication, undermining his defense.
What weight did the court give to the positive identification by witnesses?	The court gave significant weight to the positive identification by witnesses, especially those who were familiar with the accused and had no ill motive to falsely accuse him. Positive testimony generally prevails over defenses such as alibi or denial.
Can a victim’s testimony alone lead to a conviction?	Yes, a victim’s testimony can lead to a conviction, especially when it is credible, consistent, and corroborated by other evidence. In this case, Evelyn’s testimony, supported by medical evidence and other witness accounts, was sufficient to establish Alabado’s guilt.
What is the difference between murder and frustrated murder?	Murder is the unlawful killing of another person with malice aforethought, while frustrated murder is when the accused performs all the acts of execution that would produce the crime of murder as a consequence, but it is not produced due to causes independent of the accused’s will. The key difference lies in whether the victim dies.
What are the implications of this case for future criminal proceedings?	This case reinforces the importance of positive identification by credible witnesses and the consideration of treachery as a qualifying circumstance in murder cases. It also highlights that unsubstantiated defenses like intoxication or denial are unlikely to succeed against strong evidence.

The Supreme Court’s decision in *People v. Alabado* serves as a strong precedent for cases involving violent crimes and the significance of positive identification. It underscores the importance of credible eyewitness testimony and the application of legal principles like treachery in Philippine criminal law. This ruling remains a cornerstone in ensuring justice and upholding the rule of law.

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: People of the Philippines, vs. Randy Alabado y David, 44305