GR 112264; (November, 1995) (Digest)
G.R. No. 112264 November 10, 1995
People of the Philippines vs. Arthur Pidia y Dacara, Bernardo Ruiz y Repinan, and Romeo Cruz
FACTS
On February 24, 1991, five armed men robbed the house of spouses Tetsuzo and Rowena Yamamoto in Muntinlupa. During the robbery, Tetsuzo was shot and killed, and cash and jewelry valued at P90,000 were taken. The househelp, Alicia Espelita, witnessed the events. Following leads, Rowena Yamamoto and witness Bernadette Cuenco, accompanied by police agents, went to Bautista Street, Bayanan, Muntinlupa, on March 11, 1991. There, they identified and caused the arrest of Arthur Pidia, whom they recognized as the gunman. Subsequent police investigation, including a confession from Pidia, led to the identification and arrest of co-accused Bernardo Ruiz and Romeo Cruz. Espelita identified Cruz as the man who pulled her hair and forced her back into the house, and Ruiz as the man she saw standing at the terrace.
ISSUE
Whether the guilt of appellants Arthur Pidia, Bernardo Ruiz, and Romeo Cruz for the crime of Robbery with Homicide was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The defense of alibi proffered by the appellants cannot prevail over their positive identification by prosecution witnesses. Rowena Yamamoto and Alicia Espelita provided clear and credible testimonies identifying the appellants’ participation. Pidia was positively identified as the shooter by Rowena, both at the scene of the arrest and in open court. Espelita’s identification of Ruiz and Cruz during police line-ups and in court was categorical and consistent. The Court found no improper motive for the witnesses to falsely testify against the appellants.
The legal logic rests on the strength of positive identification, which, when credible and consistent, is sufficient to support a conviction. The appellants’ alibis were inherently weak, as they failed to demonstrate the physical impossibility of their presence at the crime scene. The Court also ruled that the killing of Tetsuzo Yamamoto was a direct consequence of the robbery, establishing the complex crime of Robbery with Homicide under Article 294(1) of the Revised Penal Code. All conspirators are liable for the special complex crime as the act of one is the act of all. The penalty of reclusion perpetua and the awarded damages were thus affirmed.