G.R. No. L-52119. April 24, 1989.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENJAMIN PADILLA, alias Conang, defendant-appellant.

FACTS

The case involves the robbery and killing of spouses Crisostomo Amarillo and Anita Galamgam on May 6, 1976, in San Nicolas, Pangasinan. The spouses, engaged in the buy-and-sell of gold, were carrying a substantial amount of cash and jewelry while walking home. They were followed and attacked by Mateo Padilla, Boy Batin (at large), and appellant Benjamin Padilla. Mateo hacked Crisostomo with a bolo, while Batin attacked and killed Anita as she tried to flee. While the victims were prostrate, appellant Benjamin Padilla took the money tucked in Crisostomo’s waist. Francisco Doton, who was cutting grass nearby, witnessed the incident. Mateo ordered Doton to pick up a bag and cover the bloodstains, threatening to kill him if he reported the crime. Doton complied, later discovering money in the bag, which he kept and partially deposited in a bank.
An information for robbery with double homicide was filed against Mateo Padilla, Benjamin Padilla, Francisco Doton, and Boy Batin. During trial, Doton was discharged to become a state witness. The trial court convicted Mateo and Benjamin Padilla, sentencing them to reclusion perpetua and ordering them to pay indemnity. Only Benjamin Padilla appealed.

ISSUE

The main issue is whether the trial court erred in convicting appellant Benjamin Padilla based primarily on the testimony of discharged co-accused Francisco Doton, and in finding his guilt proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction, with a modification increasing the civil indemnity. The Court upheld the discharge of Francisco Doton as a state witness. Appellant argued Doton was not the least guilty and his testimony was incredible. The Court ruled that for discharge under the Rules, the witness must not appear to be the most guilty. Doton’s role was that of an accessory or, at most, a co-principal by presence, but he did not inflict the fatal wounds or directly participate in the robbery. Thus, he was qualified as a state witness.
The Court found Doton’s testimony credible despite alleged inconsistencies. The contradictions pertained to minor details, which instead enhanced his credibility by showing natural narration. His initial fear explained his delayed disclosure about the money. His positive identification of appellant, whom he later pointed out at his residence, was deemed reliable. The defense of alibi presented by appellant and Mateo Padilla failed. The Court noted that even if they were at their homes or a fiesta earlier, it was still physically possible for them to have committed the crime at the nearby barangay. Positive identification prevails over alibi. Therefore, appellant’s guilt for robbery with double homicide was proven beyond reasonable doubt.