G.R. No. 86217 October 31, 1990
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RUBEN CRUZ, JR. y DELAMIDA, defendant-appellant.

FACTS

The accused, Ruben Cruz, Jr., was charged with Robbery with Homicide under P.D. 532. The information alleged that on March 4, 1987, in Valenzuela, Metro Manila, Cruz and four others, conspiring and mutually helping one another, robbed passengers on a jeepney. During the robbery, one of the victims, Cleofe Tojino, was stabbed, resulting in her death. Only Cruz was arraigned, pleading not guilty, while his co-accused remained at large. The prosecution presented eyewitness Romeo Castañeda, who testified that he was at the Karuhatan market that evening. Cruz approached him to light a cigarette, allowing Castañeda a clear view of his face under sufficient lighting. They later boarded the same passenger jeepney. During the trip, a holdup was announced. Cruz drew a bladed weapon and took the passengers’ personal effects. After the robbers alighted, Castañeda discovered that Cleofe Tojino had been stabbed. She later died from her wounds. Castañeda positively identified Cruz during a police follow-up operation the next day.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused, Ruben Cruz, Jr., for the crime of Robbery with Homicide beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, emphasizing that such findings are entitled to great weight. The positive identification by eyewitness Romeo Castañeda was deemed credible and reliable. Castañeda had a clear opportunity to observe Cruz at close range when his cigarette was lit under adequate light and again during the holdup inside the illuminated jeepney. His subsequent identification of Cruz to the police was prompt and consistent. The defense of alibi proffered by Cruz was rejected. The Court reiterated the settled doctrine that alibi cannot prevail over positive identification, especially when, as here, the accused failed to prove it was physically impossible for him to be at the crime scene. His claimed location was within the same municipality and easily accessible. The Court also found conspiracy sufficiently established by the collective actions of Cruz and his companions—one announcing the holdup while Cruz and others simultaneously employed intimidation and violence to carry out the robbery, which directly resulted in the victim’s death. The penalty of reclusion perpetua was affirmed, with the civil indemnity increased to P50,000.00 in accordance with prevailing jurisprudence.