People v. Gomez
REITERATIONFacts
The Antecedents: On January 2, 1989, two Metrobank armored vans carrying P7,005,000.00 were held up by heavily armed men in Calamba, Laguna. During the incident, a policeman, Sgt. Anchito Yu, and a civilian, Romulo Mercado, were killed. Three of the holduppers were killed by responding policemen, and part of the loot was recovered. Firearms used in the hold-up were traced to military personnel, including SN1 Cenon Lentic, Jr. and Cpl. Joel Cataque. Procedural History: An information for robbery with homicide was filed against several accused, including Mario Teves. Initially, only Lentic and Cataque were arrested. Cataque was acquitted due to lack of identification. Lentic was convicted but his appeal was dismissed for failure to file a brief. Mario Teves was arrested later and tried separately. The Regional Trial Court (RTC) of Laguna convicted Mario Teves of robbery with homicide and sentenced him to reclusion perpetua, with civil indemnities. The RTC found Teves guilty based on the positive identification by witnesses Joselito Molina and Gilmore Amparado, who testified that Teves was seen aiding in loading the money into a jeep and riding in a getaway car. The RTC disregarded Teves' defense of alibi and considered his flight as evidence of guilt. The Petition: Mario Teves appealed the RTC decision, imputing errors to the trial court in finding him guilty based on alleged positive identification, in discrediting his alibi, and in awarding monetary damages. He argued that the identification was improbable and inconsistent, that his alibi was competently proven, and that there was no evidence of conspiracy.
Issue(s)
Whether the positive identification of the accused-appellant Mario Teves by prosecution witnesses Joselito Molina and Gilmore Amparado is sufficient to sustain his conviction for robbery with homicide. Whether the defense of alibi interposed by the accused-appellant Mario Teves was sufficiently proven to overcome his positive identification. Whether the accused-appellant Mario Teves' flight from his military unit and failure to surrender constitute evidence of guilt.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding Mario Teves guilty beyond reasonable doubt of the crime of robbery with homicide. The Court dismissed the appeal for lack of merit.
Ratio Decidendi
On the issue of positive identification: The Court held that the positive identification of Mario Teves by prosecution witnesses Joselito Molina and Gilmore Amparado was sufficient to sustain his conviction. The Court reiterated the principle that appellate courts generally will not disturb the findings of the trial court on the credibility of witnesses, as the trial court is in a better position to observe their deportment and manner of testifying. The testimonies of Molina and Amparado were found to be credible and consistent on the essential fact that Teves was present and participated in the robbery. Any minor inconsistencies were considered to strengthen, not weaken, their credibility. The Court emphasized that the identification was made in broad daylight and from vantage positions, making it reliable even after the lapse of time. The Court also noted that the defense failed to establish any ill-motive or bias on the part of the witnesses that would cast doubt on their testimonies. On the defense of alibi: The Court found Mario Teves' defense of alibi to be unsubstantiated and unconvincing. The Court noted that for alibi to prosper, the evidence must be clear and convincing, precluding the possibility of the accused's presence at the scene of the crime. Teves failed to present corroborating witnesses, such as Sgt. Biano Flaviano or his in-laws, to support his claim of being in Angeles City during the commission of the crime. His failure to present such witnesses strengthened the view that his alibi was a concocted tale. The Court reiterated the fundamental dictum that the defense of alibi cannot prevail over positive identification. On the conduct of flight: The Court considered Mario Teves' conduct after the robbery as further evidence of his guilt. By his own admission, he went AWOL from his military unit and fled to Davao, never surrendering. His explanation for his flight was deemed unsatisfactory and unconvincing. The Court stated that flight, when unexplained, is competent evidence from which an inference of guilt may be drawn, citing the proverb that the wicked flee even when no man pursueth.
Main Doctrine
The defense of alibi cannot prevail over positive identification by credible witnesses. Flight of the accused, when unexplained, is competent evidence to indicate guilt.