People v. Soriano
REITERATIONFacts
The Antecedents: Near midnight of August 11, 1980, Leonora Corpuz was alerted by her dog's barking. Investigating with her son, Marcelino Corpuz, and brother-in-law, Natalio Solomon, they observed pebbles being thrown at a tree and the dog moving towards a camarin. The dog returned, appearing poisoned. While attending to the dog, two men, identified as Roberto Soriano and Salvador Mejia, appeared, brandishing firearms and ordering them not to move. Soriano then shot Marcelino Corpuz. Mejia was beside Soriano, and a third individual, Restituto Ferrer, was farther away. Soriano and Mejia then took the dog and fled. Marcelino Corpuz was pronounced dead on arrival at the hospital. Procedural History: The following day, investigators documented the crime scene and recovered evidence, including an empty carbine shell and dried fish with suspected poison. Leonora Corpuz identified Soriano, Mejia, and Ferrer to the police, requesting a delay in filing charges due to the suspects' alleged notoriety. An information for robbery with homicide was filed on January 4, 1982, against the three. Soriano jumped bail and was tried in absentia. The Regional Trial Court (RTC) found Soriano and Mejia guilty beyond reasonable doubt as co-conspirators, sentencing them to reclusion perpetua, and ordering them to indemnify the heirs of the victim. Restituto Ferrer was acquitted due to reasonable doubt. Soriano died from a gunshot wound on December 17, 1985, prior to the promulgation of the RTC judgment on April 17, 1986. The Petition: Accused-appellants Roberto Soriano and Salvador Mejia appealed their conviction, primarily challenging the identification made by Leonora Corpuz and Natalio Solomon. They argued the identification was fabricated, citing a police blotter entry stating the suspects were not personally known to the victim's mother and the delay in the execution of affidavits.
Issue(s)
Whether the identification of the accused-appellants by the prosecution witnesses was credible and sufficient for conviction. Whether the defense of alibi, if interposed, could overcome the positive identification of the accused. Whether the death of an accused prior to the promulgation of judgment affects his criminal liability. Whether the civil indemnity awarded was proper.
Ruling
The Supreme Court affirmed the conviction of Salvador Mejia, deleted the conviction of Roberto Soriano due to his death, and increased the civil indemnity to P50,000.00. The Court ruled that the identification of the accused-appellants was credible and sufficient for conviction, rejecting the defense's arguments regarding the police blotter entry and the delay in affidavit execution. The Court also held that the death of Soriano prior to judgment promulgation extinguished his criminal liability.
Ratio Decidendi
On the credibility of identification: The Court found no reason to doubt the accuracy of the identification made by Leonora Corpuz and Natalio Solomon. Both witnesses were in a position to recognize the appellants due to the well-lit conditions (fluorescent lamps inside the house and a 100-watt bulb outside) and the close proximity (about two meters) at the time of the incident. Leonora Corpuz recognized Roberto Soriano as a former student and Salvador Mejia as someone she frequently saw in the barangay. Natalio Solomon had known both appellants for several years. Their immediate identification of the suspects to the police the day after the crime further bolstered their credibility. The Court dismissed the defense's reliance on the police blotter entry, noting it was not presented in court and was not made by the investigators who received the information. The delay in executing formal affidavits was also explained by the witnesses' fear of retaliation from the suspects, who had unsavory reputations, until they were apprehended. On the defense of alibi: The Court reiterated the established doctrine that the defense of alibi cannot prevail against positive identification by credible witnesses. The appellants' alibi was rejected because it was contradicted by the direct and positive identification made by Leonora Corpuz and Natalio Solomon. The Court emphasized that for alibi to be considered, it must be so convincing as to leave no doubt that the accused could not have been present at the scene of the crime, which was not the case here. The appellants failed to present persuasive evidence demonstrating the physical impossibility of their presence at the crime scene. On the extinction of criminal liability due to death: The Court acknowledged that Roberto Soriano died from a gunshot wound on December 17, 1985, prior to the promulgation of the RTC judgment on April 17, 1986. Citing Article 89 (1) of the Revised Penal Code, the Court held that the death of an accused before final judgment extinguishes his criminal liability, both personal and pecuniary. Therefore, Soriano's conviction was deleted. On civil indemnity: The Court increased the civil indemnity awarded to the heirs of the victim, Marcelino Corpuz, from P30,000.00 to P50,000.00, in line with current jurisprudence at the time of the decision.
Main Doctrine
The defense of alibi cannot stand against positive identification by credible witnesses, especially when the identification is corroborated by the physical impossibility of the accused being at the scene of the crime. The death of an accused prior to promulgation of judgment extinguishes criminal liability.