People v. Trilles
REITERATIONFacts
The Antecedents: Appellants Domingo Trilles, Silvestre Trilles, Igmidio Bibliañas, and Epitacio Riofrir, Jr. were charged with Robbery with Homicide for allegedly conspiring to enter the house of Vicente Rellama, steal cash and personal properties, and kill him on January 5, 1991. The prosecution presented eyewitnesses Felix Repia and Leopoldo Balde who testified that they saw the appellants inside the victim's house, demanding money, ransacking a wooden box, and subsequently hacking the victim to death. The victim sustained multiple hack wounds, resulting in his death. The stolen items included P65,000.00 in cash, a transistor radio, a flashlight, a Seiko wristwatch, and half a sack of rice. The defense invoked alibi for each of the appellants. Procedural History: The Regional Trial Court, Branch 13, Ligao, Albay, found all four appellants guilty beyond reasonable doubt of Robbery with Homicide and sentenced each to suffer the penalty of reclusion perpetua, ordering them to proportionately indemnify the heirs of the victim in the amount of P80,000.00 and to pay costs. The Petition: The appellants appealed their conviction, arguing that the trial court erred in giving weight to the inconsistent, incredible, and contradicting testimonies of the prosecution witnesses and in finding them guilty beyond reasonable doubt despite weak evidence.
Issue(s)
Whether the trial court erred in giving weight to the inconsistent, incredible, and contradicting testimonies of the prosecution witnesses. Whether the trial court erred in finding the four accused guilty beyond reasonable doubt of the crime charged despite the shaky and weak evidence for the prosecution. Whether the alibi of the accused is sufficient to overcome their positive identification by eyewitnesses.
Ruling
The Court affirmed the decision of the trial court finding the appellants guilty of Robbery with Homicide, sentencing each to suffer the penalty of reclusion perpetua. The Court modified the civil indemnity awarded to the heirs of the victim, reducing it from P80,000.00 to P50,000.00.
Ratio Decidendi
On the alleged inconsistencies in the testimonies of prosecution witnesses: The Court found the inconsistencies pointed out by the appellants to be trivial and inconsequential. The uncertainty regarding the exact amount of money demanded and the omission of a specific purpose for a witness's presence did not destroy their credibility, especially in light of their positive and categorical identification of the appellants as the perpetrators. The Court noted that the eyewitnesses resided in the same or adjoining barangays as the appellants, and some were even related by affinity, negating any improper motive for false accusations. The Court also addressed the initial omission of details when reporting the crime, attributing it to the shock of witnessing an atrocious act, and emphasized that the details were later recounted to the authorities. On the alleged shaky and weak evidence for the prosecution: The Court found the evidence for the prosecution to be strong, particularly the positive identification of the appellants by two eyewitnesses, Felix Repia and Leopoldo Balde. These witnesses positively identified the appellants as the ones who entered the victim's house, demanded money, and inflicted fatal hack wounds. The Court found no improper motive for the eyewitnesses to falsely implicate the appellants, strengthening the prosecution's case. The Court also noted that the appellants' alibis were not substantiated by evidence that would make it physically impossible for them to be at the scene of the crime. On the alibi of the accused: The Court rejected the alibis presented by the appellants. It held that for an alibi to be credible, it must not only be proven that the accused was elsewhere but also that it was physically impossible for him to have been at the scene of the crime at the time of its commission. In this case, the distances of the appellants' claimed locations from the victim's house were relatively short (a kilometer or half a kilometer), making it physically possible for them to have been present at the crime scene. Therefore, their alibis could not overcome the positive identification made by the prosecution witnesses.
Main Doctrine
The Court affirmed the conviction for Robbery with Homicide, holding that the alibi of the accused was unavailing against their positive identification by eyewitnesses, and modified the civil indemnity awarded.