GR 102078; (May, 1996) (Digest)
G.R. No. 102078 May 15, 1996
People of the Philippines, plaintiff-appellee, vs. Rolando Feliciano y Agustin, accused-appellant.
FACTS
On May 30, 1988, accused-appellant Rolando Feliciano, his brother Rogelio, and an unidentified companion went to the Quezon City residence of Rosario Fariñas under the pretext of waiting for her son-in-law. They were invited to lunch. During the meal, the group suddenly initiated a robbery, brandishing knives and a gun. Without provocation, Rolando Feliciano stabbed Rosario Fariñas three times, causing her death. The robbers then forced Marciano Fariñas to surrender cash and took an undetermined amount of U.S. dollars from Rosario’s room. When Marciano refused to give more money, Rolando, upon Rogelio’s instruction, stabbed him multiple times. Marciano survived after treatment.
Rolando Feliciano was later arrested and charged with Robbery with Homicide. The prosecution’s case relied on the eyewitness testimonies of helper Nelia Basilio and victim Marciano Fariñas. The defense presented alibi. The Regional Trial Court convicted Feliciano and sentenced him to reclusion perpetua, prompting this appeal.
ISSUE
Whether the trial court erred in convicting accused-appellant Rolando Feliciano of the crime of Robbery with Homicide based on the evidence presented.
RULING
The Supreme Court affirmed the conviction. The Court found the testimonies of eyewitnesses Nelia Basilio and Marciano Fariñas to be credible, consistent, and sufficient to establish Feliciano’s guilt beyond reasonable doubt. The defense’s claim that Nelia’s initial affidavit did not name Rolando was not fatal; she executed a subsequent affidavit and provided clear, positive identification in court, which prevails over earlier omissions. Her proximity to the crime and detailed account of Feliciano stabbing Rosario were compelling.
The Court rejected the defense of alibi as weak and unsubstantiated, especially in light of the strong positive identification. The crime committed was Robbery with Homicide under Article 294(1) of the Revised Penal Code, as the homicide was perpetrated by reason or on the occasion of the robbery. The Court noted the presence of the aggravating circumstance of dwelling, as the crime was committed in the victims’ home. However, since the crime was punishable by the single indivisible penalty of reclusion perpetua due to the constitutional prohibition of the death penalty at the time, the penalty remained reclusion perpetua irrespective of aggravating circumstances. The trial court’s decision was affirmed in toto.