People v. Feliciano
REITERATIONFacts
The Antecedents: On May 30, 1988, Rolando Feliciano, his brother Rogelio Feliciano, and an unidentified male entered the house of 68-year-old Rosario Fariñas, claiming to wait for her son-in-law. Present were Rosario Fariñas and her helper, Nelia Basilio. Upon entering the dining room, Rolando Feliciano held Rosario Fariñas at knifepoint, Rogelio Feliciano held Marciano Fariñas (Rosario's brother) at gunpoint, and the third man held Nelia Basilio at knifepoint. Rolando Feliciano then stabbed Rosario Fariñas three times in the chest, with the first wound being fatal. The robbers took P1,000.00 and $200.00 from Marciano Fariñas and an undetermined amount of U.S. dollars from Rosario's room. When Marciano Fariñas refused to give more money, Rolando Feliciano, on Rogelio's instruction, stabbed Marciano Fariñas several times. Marciano Fariñas survived after 23 days of hospitalization. Rosario Fariñas died from severe hemorrhage secondary to stab wounds. Procedural History: Rolando Feliciano was arrested on December 5, 1990, after being wounded during an escape attempt. His co-accused, Rogelio Feliciano and John Doe, eluded arrest. Rolando Feliciano was charged with Robbery with Homicide. The prosecution relied on the eyewitness accounts of Nelia Basilio and Marciano Fariñas. The defense presented alibi. The Regional Trial Court (RTC), Branch 104 of Quezon City, convicted Rolando Feliciano of Robbery with Homicide and sentenced him to death, commuted to reclusion perpetua due to the constitutional prohibition. The RTC ordered him to pay damages and costs. The Petition: Rolando Feliciano appealed, contending that his guilt and participation were not proven beyond reasonable doubt. He argued that Nelia Basilio's testimony was perjured and that her initial affidavit did not name him. He also faulted the RTC for not giving credence to his defense of alibi.
Issue(s)
Whether the guilt of the accused-appellant Rolando Feliciano was proven beyond reasonable doubt, including the assessment of eyewitness testimony. Whether the defense of alibi was sufficiently established, considering the inconsistencies in supporting testimonies. Whether the aggravating circumstance of dwelling should be appreciated in the context of robbery with homicide, and its effect on the penalty.
Ruling
The Supreme Court affirmed the decision of the trial court in toto, finding Rolando Feliciano guilty beyond reasonable doubt of the crime of Robbery with Homicide and sentencing him to suffer the penalty of reclusion perpetua.
Ratio Decidendi
On the issue of guilt and participation: The Court found that the guilt of Rolando Feliciano was proven beyond reasonable doubt. While Nelia Basilio's initial affidavit did not name Rolando Feliciano, a subsequent affidavit executed on December 9, 1990, categorically identified him as the person who stabbed Rosario Fariñas. Furthermore, Nelia Basilio's direct testimony in court unequivocally identified Rolando Feliciano as one of the robbers and the one who stabbed the victim. The Court gave credence to Nelia Basilio's testimony, noting that she was acquainted with the appellant and had no improper motive to implicate him. The Court emphasized that it is not necessary for an accused's name to be specifically stated in an initial affidavit, as long as the attacker is unequivocally identified during trial. The positive identification by an eyewitness, especially one who was acquainted with the accused, is given great weight. On the defense of alibi: The Court found the defense of alibi to be incredible and uncorroborated. The testimonies of Rolando Feliciano's wife and a neighbor were inconsistent regarding his whereabouts at the time of the crime. His wife claimed he was out buying a banca, while the neighbor saw him only in the afternoon. These discrepancies, coupled with the positive identification by Nelia Basilio, rendered the alibi unavailing. The Court reiterated that alibi must be supported by credible and unimpeachable evidence and must be so convincing as to preclude any doubt as to its truthfulness, which was not the case here. On the aggravating circumstance of dwelling: The Court found the aggravating circumstance of dwelling to be present. The crime was committed inside the residence of the offended party, and no provocation was given by the victim. The Court explained that dwelling can be appreciated as aggravating in robbery with homicide because the commission of such a crime does not necessitate the violation of the sanctity of a home, and the deliberate invasion of a domicile shows greater perversity on the part of the offender. However, the Court noted that with the imposition of the penalty of reclusion perpetua, which is now the single and indivisible penalty for robbery with homicide, the presence of aggravating circumstances does not alter the imposable penalty.
Main Doctrine
The crime of Robbery with Homicide is a special complex crime punishable by reclusion perpetua to death under Article 294, paragraph 1 of the Revised Penal Code. The penalty of reclusion perpetua is now imposed regardless of aggravating or mitigating circumstances due to the constitutional prohibition against the death penalty.