GR 102981; (April, 1995) (Digest)
G.R. Nos. 102981-82. April 29, 1995.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TEODORO ESMALE y BADION and JUAN TRESVALLES, JR. y TROPE, accused. JUAN TRESVALLES, JR. y TROPE, accused-appellant.
FACTS
On September 27, 1985, a passenger jeepney in Marikina was held up by five men. During the robbery, one passenger, Leonardo Diwa, resisted and was stabbed to death. The accused, Teodoro Esmale and Juan Tresvalles, Jr., were charged with Robbery with Homicide. The prosecution presented two eyewitnesses, Reynaldo Balbastro and Antonio Sosa, who positively identified both accused as among the perpetrators. Esmale was arrested and initially confessed, implicating Tresvalles, but later recanted, claiming the confession was extracted through torture.
The defense consisted of denial and alibi. Esmale denied participation. Tresvalles claimed he was at the house of a relative, Lt. Democrito Alibadbad, Jr., doing construction work from September 26 to 28, 1985. Lt. Alibadbad corroborated this alibi. The trial court convicted both accused, giving greater weight to the positive identification by the eyewitnesses and dismissing the alibi as weak and unconvincing.
ISSUE
Whether the guilt of accused-appellant Juan Tresvalles, Jr. for the crime of Robbery with Homicide was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment that the positive identification by the eyewitnesses was credible and sufficient to establish guilt. The witnesses had ample opportunity to observe the accused during the extended incident, which occurred early in the evening under sufficient lighting conditions inside the jeepney. Their testimonies were consistent and remained unshaken on cross-examination.
The Court rejected the defense of alibi. For alibi to prevail, it must be demonstrated that the accused was so far away that it was physically impossible for him to have been at the scene of the crime. Tresvalles’s claimed location was not shown to be such an impossible distance from the crime scene in Marikina. Furthermore, alibi cannot stand against positive identification, which carries greater weight. The corroboration by a relative, Lt. Alibadbad, was rightly viewed by the trial court with caution due to potential bias. The constitutional presumption of innocence was successfully overcome by the prosecution’s evidence, which met the required quantum of proof beyond reasonable doubt.