People v. Urquia, Jr.
REITERATIONFacts
The Antecedents: The accused, including Ricardo Urquia, Jr. alias "Cardohay" and Leoncito Intoy alias "Dodo", were charged with Robbery with Multiple Homicide. The amended information alleged that on October 1, 1985, at around 10:00 PM, the accused, armed with various weapons, conspired to enter the house of Barangay Captain Exuperancio Cosmiano and his wife, Sixta A. Cosmiano. They allegedly hogtied the victims, including their children Nonita A. Cosmiano and Cesario A. Cosmiano, stole cash and personal properties, and then killed all four victims with multiple stab wounds. The prosecution presented Maricor Coleto, a niece of the victims and a resident of their household, as the sole eyewitness. Coleto testified that she recognized Ricardo Urquia, Jr. as the one who stabbed Exuperancio Cosmiano, Virgilio Vallejo and Rolando Zambales as those who entered the kitchen and ordered the victims to lie down, and Leoncito Intoy as the one who warned the group of Exuperancio's arrival. The post-mortem examination revealed that the victims sustained multiple fatal injuries. Procedural History: The Regional Trial Court, Branch 27, Tandag, Surigao del Sur, found Ricardo Urquia, Jr., Virgilio Vallejo, Leoncito Intoy, and Rolando Zambales guilty beyond reasonable doubt as principals of Robbery with Multiple Homicide. Each was sentenced to suffer the penalty of reclusion perpetua and to pay solidary civil indemnity. Juan Parajes was acquitted for lack of sufficient evidence. The case against Rudy Miranda and Bernardino Cuartero was dismissed due to insufficient evidence. Only Ricardo Urquia, Jr. and Leoncito Intoy appealed. However, Leoncito Intoy's appeal was dismissed for failure to file the appellant's brief. The Petition: Ricardo Urquia, Jr. appealed his conviction, raising errors concerning the trial court's failure to sustain his alibi, its reliance on the eyewitness identification, its assumption of a planned robbery with vendetta as motive, and the alleged absence of proof beyond reasonable doubt.
Issue(s)
Whether the trial court erred in not sustaining the defense of alibi by accused-appellant Ricardo Urquia, Jr. and in giving weight to the supposed positive identification of the appellant by the lone eyewitness. Whether the trial court erred in assuming that the robbery and massacre were well-planned with vendetta as a possible motive. Whether the trial court erred in convicting the accused-appellant despite the absence of proof beyond reasonable doubt.
Ruling
The Court affirmed the decision of the Regional Trial Court, finding Ricardo Urquia, Jr. guilty beyond reasonable doubt of the crime of robbery with homicide. The civil indemnity to the heirs of the victims was modified to P50,000.00 for each deceased, totaling P200,000.00. The appeal of Leoncito Intoy was dismissed.
Ratio Decidendi
On the issue of alibi and positive identification: The Court held that the defense of alibi is inherently weak and cannot prevail against the positive identification of the appellant by a credible eyewitness. Maricor Coleto, the sole eyewitness, positively identified Ricardo Urquia, Jr. as one of the perpetrators and the one who stabbed Exuperancio Cosmiano. While Coleto did not know Urquia, Jr.'s name at the time of her affidavit, she recognized him by his physical appearance and was able to identify him in court. The Court found her testimony credible, noting that her failure to mention certain details in her affidavit was not fatal, as affidavits are often incomplete. The Court also found that the circumstances of the crime, including the lighting conditions in the house, were conducive to proper identification. The appellant's claim that Coleto was motivated by a feud between his family and the Azarcons was unsubstantiated and deemed insufficient to discredit her testimony. The Court reiterated that the testimony of a single eyewitness, if found convincing and trustworthy, is sufficient to support a conviction beyond reasonable doubt. On the issue of motive and planning: The Court found that the trial court's assumption of a well-planned robbery with vendetta as a possible motive was not erroneous. The amended information itself alleged evident premeditation, treachery, and abuse of superior strength, indicating a degree of planning. While the appellant denied any motive, the prosecution presented evidence suggesting a conspiracy among the accused. The Court noted that the victims were hogtied and defenseless when attacked, supporting the conclusion that the crime was not a spontaneous act but a planned commission of robbery with homicide. The Court also pointed out that the appellant's claim of being in Surigao City at the time of the crime was not physically impossible to overcome, given the travel time between Cantilan and Surigao City, thus casting doubt on his alibi. On the issue of proof beyond reasonable doubt: The Court concluded that the guilt of the appellant was established beyond reasonable doubt. The positive identification by Maricor Coleto, coupled with the rejection of the appellant's alibi, was sufficient to warrant a conviction. The Court found Coleto's testimony to be sincere, logical, probable, and credible, as observed by the trial court. The Court also reiterated the established jurisprudence that the offense is denominated as robbery with homicide regardless of the number of homicides or injuries committed. The Court found no reason to doubt the trial court's findings of fact and its appreciation of the evidence presented.
Main Doctrine
The defense of alibi, being inherently weak, cannot prevail against the prosecution's positive identification of the appellant by a credible eyewitness. For alibi to prosper, it must not only be shown that the accused was somewhere else when the crime was committed, but also that it was physically impossible for him to have been at the scene of the crime.