G.R. No. L-41344 June 25, 1980
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LEONIDES PAREDES, PAULINO DANLAG alias GENE and FELIPE PAYOT alias RUDY, accused; LEONIDES PAREDES, defendant-appellant.

FACTS

On July 9, 1971, in Bukidnon, six armed men, one in a PC uniform, robbed the house of Teodulo Galarpe. They divested him of cash, ransacked the house for valuables, and took several hostages, including Galarpe and his daughters. The robbers used Galarpe’s truck to flee. During the escape, near a barricade erected by barrio folks, the robbers opened fire. Pedro Flores, who flagged down the truck, was shot and killed. Mrs. Elsie Velez, a hostage, was also fatally wounded during the incident. The accused, Leonides Paredes, was positively identified by witnesses as one of the armed perpetrators.
Initially, Paredes pleaded not guilty, then changed his plea to guilty, but later withdrew it before trial to re-enter a plea of not guilty. After trial, the Court of First Instance convicted Paredes of robbery with homicide. The court found the aggravating circumstances of band and use of a motor vehicle, with no mitigating circumstances, and imposed the death penalty. His co-accused were acquitted. Paredes appealed, contesting the sufficiency of the evidence against him.

ISSUE

Was the evidence sufficient to prove the guilt of Leonides Paredes for the crime of robbery with homicide beyond reasonable doubt?

RULING

Yes, the Supreme Court affirmed the conviction and the imposition of the death penalty. The Court meticulously examined the evidence and found the prosecution’s case overwhelming. Paredes was positively identified by multiple credible eyewitnesses, including the victims, who had no motive to falsely testify against him. This positive identification categorically placed him at the scene of the crime as an active participant.
The Court rejected Paredes’s defense of alibi as inherently weak and unworthy of credit. For alibi to prevail, it must be demonstrated that the accused was so far away that it was physically impossible for him to have been at the crime scene. Paredes failed to meet this stringent requirement. His claim of being elsewhere was further undermined by the testimony of a witness who stated that one of the robbers advised Paredes to leave the area after the crime, directly linking him to the conspiracy. The Court also noted the admissibility and corroboration of his extrajudicial confession, which, together with the evidence of the corpus delicti, solidified his guilt. His initial plea of guilty, though later withdrawn, was also considered as a further indication of his culpability. The crime was correctly classified as robbery with homicide, aggravated by band and the use of a motor vehicle, warranting the supreme penalty.