People v. Corpus
REITERATIONFacts
The Antecedents: On October 15, 1989, at dawn, in Barangay Bolintaguan, San Quintin, Pangasinan, Rolando Corpus y Mina and Bayani Santos y Vidad, along with three other unidentified individuals, allegedly conspired to commit robbery with homicide. They entered the house of Eustaquio P. Bautista, Sr., armed with firearms. They looted various valuables, including a Sony T.V. set, Betamax machine, Sansui Stereo Component, Seiko wrist watch, assorted clothes, jewelry, shoes, food-stuffs, and cash money, with an approximate value of P150,000.00. During the robbery, they took Arsenio Bautista, son of Eustaquio P. Bautista, Sr., with them. Arsenio Bautista was later found dead in Lumayao, covered with hay, with his hands tied behind his back. An autopsy revealed he sustained 24 stab wounds, with two being fatal, causing acute hemorrhage. The sidecar of the stolen Yamaha motorcycle was recovered in Laoag. Procedural History: The Provincial Prosecutor of Pangasinan filed an information for Robbery with Homicide against appellants Rolando Corpuz y Mina, Bayani Santos y Vidad, and three others. Appellants pleaded not guilty. After trial, the Regional Trial Court, Branch 52, Tayug, Pangasinan, rendered judgment finding appellants guilty of the offense charged and sentencing them to suffer the penalty of reclusion perpetua, with credit for the full duration of their preventive imprisonment. The Petition: Appellants appealed the decision of the trial court.
Issue(s)
Whether the guilt of the accused-appellants for the crime of Robbery with Homicide has been proven beyond reasonable doubt. Whether the defense of alibi interposed by the accused-appellants is tenable. Whether the trial court erred in its appreciation of the evidence and in its findings of fact.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding accused-appellants Rolando Corpus y Mina and Bayani Santos y Vidad guilty of Robbery with Homicide. They were sentenced to suffer the penalty of reclusion perpetua, with full credit for their preventive imprisonment.
Ratio Decidendi
On the guilt of the accused-appellants for the crime of Robbery with Homicide: The Court gave full faith and credit to the version of the prosecution. Eustaquio Bautista, Jr. and Alberto Nacion were accosted by armed men, some masked, near their home. Eustaquio, Jr. was forced to drive his tricycle to his father's house, where the robbers, identified by Eustaquio, Sr. and Eustaquio, Jr. as the appellants, entered and looted the house. During the looting, Arsenio Bautista was awakened, apprehended, tied, and taken by the robbers. He was later found dead with multiple stab wounds. The positive identification of the appellants by the victims, Eustaquio, Sr. and Eustaquio, Jr., as the unmasked robbers who entered their house and committed the robbery, directly contradicted their defense of alibi. The Court found that the elements of robbery with homicide were established: the taking of personal property with intent to gain, by means of violence and intimidation, and that on the occasion of the robbery, homicide was committed. On the tenability of the defense of alibi: The Court rejected the defense of alibi. It is settled that the defense of alibi must fail when it is uncorroborated and contradicted by positive identification of the accused. The appellants failed to present any witness to support their claim of being in Quezon City on the date of the incident, nor did they present employment records or other corroborating evidence. Their failure to present vital evidence, such as the testimony of Eddie Mariano or Joe Ilagan, was considered a suppression of evidence that would have been adverse to their defense. Furthermore, their admission during investigation of having ransacked another house in Laoac, Pangasinan, cast further doubt on their credibility. On the trial court's appreciation of evidence and findings of fact: The Court reiterated the rule that the findings of fact of the trial court are accorded great respect and are generally sustained by the appellate courts, unless some material facts have been overlooked or misconstrued. The trial court had the opportunity to observe the demeanor of the witnesses. The Supreme Court found no attendant circumstances that would justify a departure from this rule. The identification of the appellants by the victims was positive and credible, and the evidence presented by the prosecution established their guilt beyond reasonable doubt. The trial court's assessment of the evidence was found to be sound and consistent with the established facts.
Main Doctrine
The defense of alibi is unavailing when contradicted by positive identification of the accused. The trial court's findings of fact are accorded great respect and are generally sustained by appellate courts unless material facts have been overlooked or misconstrued.