Antonio Lejano

v.
People of the Philippines
G.R No. 176389, December 14, 2010
En Banc, Abad, J:

FACTS:

On June 30, 1991 Estrellita Vizconde and her daughters Carmela and Jennifer
were brutally slain at their home in Paraaque City. The police arrested a group of suspects, 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 or NBI announced that it
had solved the crime. It presented star-witness Jessica M. Alfaro. Some of the accused testified,
denying any part in the crime and saying they were elsewhere when it took place. Webbs alibi
appeared the strongest since he claimed that he was then across the ocean in the United States of
America.
On January 4, 2000, the trial court rendered judgment, finding all the accused guilty as
charged and imposing on Webb, Lejano, Gatchalian, Fernandez, Estrada, and Rodriguez the
penalty of reclusion perpetua and on Biong, an indeterminate prison term of eleven years, four
months, and one day to twelve years. On appeal, the Court of Appeals affirmed the trial courts
decision.
ISSUE:
Whether or not Webb presented sufficient evidence to prove his alibi and rebut Alfaros
testimony that he led the others in committing the crime.

HELD:
To establish alibi, the accused must prove by positive, clear, and satisfactory
evidence that (a) he was present at another place at the time of the perpetration of the crime, and
(b) that it was physically impossible for him to be at the scene of the crime.

The trial court and the Court of Appeals expressed marked cynicism over the accuracy of
travel documents like the passport as well as the domestic and foreign records of departures and
arrivals from airports. 
If the Court were to subscribe to this extremely skeptical view, it might as well tear the
rules of evidence out of the law books and regard suspicions, surmises, or speculations as
reasons for impeaching evidence. It is not that official records, which carry the presumption of
truth of what they state, are immune to attack. The prosecution did not bother to present evidence
to impeach the entries in Webbs passport and the certifications of the Philippine
and U.S. immigration services regarding his travel to the U.S. and back.