People v. Riego y Quiozon
REITERATIONFacts
The Antecedents: On April 9, 1987, at around 9:25 PM, in Taguig, Metro Manila, Crisostomo Manalili was about to board his parked service jeep when three men rushed towards the vehicle. Appellant Reynaldo Serna, armed with a .45 caliber gun, and another accused, Jojo Torres, armed with a .38 caliber gun, attempted to grab a clutch bag from Crisostomo Manalili. Despite resistance, Serna fired three successive shots, hitting Crisostomo Manalili, who fell. Serna then grabbed the bag containing P150,000.00 and continued firing at the occupants of the jeep, hitting Virginia Manalili and Gilbert Gumabo. Domer Riego was identified as the look-out. The assailants fled with the money. Crisostomo Manalili died from gunshot wounds. Virginia Manalili and Gilbert Gumabo sustained gunshot wounds but survived due to timely medical attention. Procedural History: The Regional Trial Court of Pasig, Branch 164, found Reynaldo Serna and Domer Riego guilty beyond reasonable doubt of robbery with homicide, sentencing each to suffer reclusion perpetua and to indemnify the heirs and victims. Reynaldo Serna appealed the decision. The Petition: Reynaldo Serna appealed his conviction, raising errors concerning the trial court's finding of guilt, the admissibility of Domer Riego's confession, and the disregard of his defense.
Issue(s)
Whether the trial court erred in finding accused Reynaldo Serna guilty of robbery with homicide. Whether the trial court erred in considering the repudiated confession and/or admission of accused Domer Riego as admissible evidence. Whether the trial court erred in disregarding the defense of accused-appellant Reynaldo Serna.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding Reynaldo Serna guilty beyond reasonable doubt of robbery with homicide and sentencing him to suffer the penalty of reclusion perpetua. The Court also ordered him to indemnify the heirs of Crisostomo Manalili and the other victims.
Ratio Decidendi
On the issue of guilt for robbery with homicide: The Court found the positive identification of appellant Reynaldo Serna by prosecution witnesses Armando Marcelo, Virginia Manalili, and Gilbert Gumabo to be credible and sufficient to establish guilt beyond reasonable doubt. The illumination from a Meralco post and a Coleman lamp was deemed adequate for Marcelo to recognize the appellant, who had been observed in the vicinity for three prior nights. Marcelo's act of ducking behind his pushcart did not obstruct his view of the incident. The initial delay in Marcelo's reporting was justified by his fear of reprisal, evidenced by a threatening letter. Inconsistencies in affidavits are generally considered inferior to testimonies given in open court. The testimonies of Virginia Manalili and Gilbert Gumabo, despite their initial delay in giving statements due to their physical and emotional trauma from the incident, were also found to be credible. Gumabo's ability to witness the incident even after being shot was plausible given his positioning and prior observation. On the admissibility of Domer Riego's extra-judicial confession: The Court found that Domer Riego was assisted by counsel and was apprised of his constitutional rights when he executed his extra-judicial statement. The presence of Atty. Luis de Guzman's signature alongside Riego's on the statement, for each cautionary question, indicated a valid waiver of his rights. Riego's allegations of maltreatment were unsubstantiated, with only minor injuries presented. However, the Court noted that Riego's confession could be disregarded without altering the outcome of the appeal, as the appellant's guilt was established by other evidence. On the defense of alibi: The Court found the appellant's defense of alibi to be unmeritorious. His claimed residence in Pototan, Muntinlupa, is contiguous to Taguig, and it was not physically impossible for him to have been at the scene of the crime, as he admitted it only takes an hour by passenger jeepney to travel between the locations. The defense of alibi cannot prevail over clear and positive identification by prosecution witnesses. The appellant's request to be brought to the Manalili home was interpreted as a miscalculation of his ability to avoid identification, and his failure to appear at the preliminary investigation further weakened his defense.
Main Doctrine
The positive identification of the accused by credible witnesses, even in the absence of a co-conspirator's confession, is sufficient to establish guilt beyond reasonable doubt. Alibi, being a weak defense, cannot prevail over clear and positive identification.