People v. Mendoza y Cruz
REITERATIONFacts
The Antecedents: On April 27, 1970, at approximately 10:45 PM, a jeepney driven by Francisco Garido, with several passengers, was boarded by three men. While the jeepney was in motion, the men divested the passengers of their valuables, stabbed them, and fled. One passenger, Oscar G. Tagudin, died from his stab wounds. Other passengers, Claro Dabajo and Alicia Victoria, sustained serious stab wounds and had their wristwatches stolen. The driver, Francisco Garido, also sustained a stab wound and his earnings were missing. Procedural History: Roberto Mendoza was charged with robbery with homicide and multiple serious physical injuries. He interposed the defense of alibi, claiming he was in Bulacan at the time of the incident. His alleged common-law-wife, Belinda Diaz, testified but failed to corroborate his alibi. The trial court rejected Mendoza's alibi, gave credence to Alicia Victoria's identification of Mendoza, and convicted him of robbery with homicide, aggravated by craft and abuse of superiority. He was sentenced to death and ordered to pay indemnity and damages. Mendoza did not appeal, and the case was elevated for automatic review of the death penalty. The Petition: Counsel de oficio argued that Mendoza's guilt was not proven beyond reasonable doubt due to the failure of one victim to identify him, the alleged falsity of the driver's identification, and the inconclusiveness of Alicia Victoria's identification.
Issue(s)
Whether the guilt of the accused was proven beyond reasonable doubt, and whether the identification of the accused by the victim Alicia Victoria was sufficient and credible. Whether the trial court erred in convicting the accused of robbery with homicide and multiple serious physical injuries. Whether the death penalty was properly imposed. On civil liability regarding the stolen wristwatch.
Ruling
The Court affirmed the judgment of conviction and the imposition of the death penalty by the trial court. However, for lack of the requisite ten votes, the death penalty was commuted to reclusion perpetua. The trial court's judgment with respect to the civil liability was affirmed with modification regarding the return of Claro Dabajo's wristwatch.
Ratio Decidendi
On the issue of reasonable doubt and identification: The Court found that the identification of the accused by Alicia Victoria was credible and sufficient to establish guilt beyond reasonable doubt. Despite the defense of alibi, Victoria positively identified Mendoza as one of the malefactors who robbed and stabbed her. Her identification was based on her having seen him intently across her in the jeepney, remembering his face and his long hair at the time. The driver of the jeepney also identified Mendoza. The Court noted that no peace officer testified on how Mendoza became a suspect or how he was apprehended, but this did not negate the positive identification made by the victim. The Court also considered that Victoria identified Mendoza twice: first, about a week after the robbery when he was brought to her residence by CIS agents, and again, more than a year later, in a police lineup. The Court rejected the argument that the identification was inconclusive, emphasizing Victoria's certainty and the basis for her recollection. On the conviction for robbery with homicide and physical injuries: The Court held that the evidence sufficiently established the commission of robbery with homicide. The malefactors divested passengers of their valuables and inflicted stab wounds, resulting in the death of one victim and serious physical injuries to others. The Court reiterated the principle that in robbery with homicide, the homicide is absorbed by the robbery, and the physical injuries are also absorbed by the more serious offense of robbery with homicide, citing People vs. Maranan. Therefore, the conviction for robbery with homicide was proper. On the imposition of the death penalty: The trial court imposed the death penalty, which is the penalty for robbery with homicide when homicide results. The Court found that the elements of robbery with homicide were present and that the aggravating circumstances of craft and abuse of superiority were considered by the trial court. However, due to the lack of the requisite ten votes for the imposition of the death penalty, it was commuted to reclusion perpetua, in accordance with constitutional provisions. This commutation does not signify a doubt in the guilt of the accused but rather a procedural requirement for the imposition of the ultimate penalty. On civil liability: The Court affirmed the civil liability imposed by the trial court with a modification. It clarified that the wristwatch taken from Claro Dabajo was his Titus wristwatch valued at one hundred pesos, not that of Oscar Tagudin, from whom nothing was taken. Therefore, the accused was ordered to return Dabajo's wristwatch or pay its value, and not to pay for Tagudin's watch.
Main Doctrine
The Court affirmed the conviction for robbery with homicide and the imposition of the death penalty, but commuted it to reclusion perpetua due to lack of the requisite ten votes. The civil liability was also affirmed with modifications.