G.R. No. L-27974 February 27, 1976
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO SALILING, CONCORDIO JUMADIAO, SERGIO DIANO and RAYMUNDO VILLANUEVA, defendants-appellants.

FACTS

In the early morning of January 8, 1966, in Barrio Liberty, Catarman, Samar, Rodrigo Argenio and his family were awakened by calls from outside their house. Argenio and his wife, Amada de Pablo, recognized the voices and, upon opening the window, saw appellants Antonio Saliling, Concordio Jumadiao, Sergio Diano, and Raymundo Villanueva. Jumadiao requested to buy a chicken and enter the house. Trusting them, Argenio unbolted the door. The four immediately rushed inside the illuminated house. Saliling, without provocation, stabbed Argenio in the abdomen. As Argenio clutched his wound, Diano stabbed him in the chest. Villanueva then seized a buri bag and took a wallet containing sixty pesos. The assailants fled, with Diano threatening the family as he left. Argenio, after giving a dying declaration identifying his attackers, was taken to the hospital where he died later that day from his wounds.
At trial, the prosecution presented the eyewitness accounts of Amada de Pablo and her ten-year-old son, Carlito. The defense presented contrasting narratives. Saliling and Jumadiao claimed the stabbing occurred outside near a footbridge, alleging self-defense against an aggressive Argenio. Diano and Villanueva set up alibi, claiming they were at a birthday party at Villanueva’s father’s house at the time of the crime. They suggested the charges were fabricated due to a land dispute between their family and the victim’s landlord, Alejandro Valle.

ISSUE

The core issue is whether the guilt of appellants Concordio Jumadiao, Sergio Diano, and Raymundo Villanueva for the crime of Robbery with Homicide was proven beyond reasonable doubt.

RULING

Yes, the guilt of appellants Jumadiao, Diano, and Villanueva was established beyond reasonable doubt. The Supreme Court affirmed their conviction, modifying only the penalty for Jumadiao. The Court found the testimonies of the prosecution eyewitnesses, Amada de Pablo and Carlito Argenio, to be credible, straightforward, and consistent. Their positive identification of all four appellants as participants in the crime, committed inside their own home under lamplight, was deemed conclusive. The trial court rightly gave weight to the natural and truthful manner of the young witness, Carlito.
The defense of alibi by Diano and Villanueva was correctly rejected. For alibi to prevail, it must be shown that the accused was so far away that it was physically impossible for them to be at the scene of the crime. Their claim of being at a party in the same barrio did not meet this stringent requirement. The Court also found the claim of self-defense by Saliling and Jumadiao to be inherently unbelievable and unsupported by evidence, especially when juxtaposed with the credible prosecution narrative of a sudden and violent home invasion. The dying declaration of the victim, corroborating the eyewitness accounts, further solidified the case against the appellants. All four acted in concert, with Saliling and Diano inflicting the fatal wounds and Villanueva taking the money, making them all liable as principals. The Court sentenced Jumadiao, Diano, and Villanueva to reclusion perpetua, having considered the absence of aggravating circumstances, and affirmed the civil indemnity.