G.R. No. 113446 ; August 4, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. ELMER FEGIDERO y CORDOVA, accused-appellant.

FACTS

On the evening of March 21, 1993, Emilio Castro, carrying a bag containing cash and jewelry, boarded a passenger jeepney in Makati bound for Manila. A commotion was later observed inside the jeepney when it stopped at a gasoline station in Paco, Manila. Eyewitness Eddie Mayani saw accused-appellant Elmer Fegidero alight from the jeepney clutching a black bag, which he opened and inspected under the station’s light. The victim, Emilio Castro, was then seen bloodied and assisted out of the vehicle, shouting “Hoy, Hoy!” towards the fleeing Fegidero and stating he had been held-up. Castro was rushed to the hospital but was declared dead on arrival from multiple stab wounds.
Fegidero was pursued by bystanders, including Jose Peñaredondo and others who heard shouts of “hold-up.” During the chase, Fegidero threw the bag, which was recovered and found to contain Castro’s identification. The community eventually apprehended and mauled Fegidero. Barangay officials intervened and, upon frisking him, found a bloodied balisong knife in his pocket. He was turned over to the police. The victim’s daughter later identified the recovered bag and its contents as belonging to her deceased father.

ISSUE

Whether the prosecution proved beyond reasonable doubt that accused-appellant Elmer Fegidero is guilty of the special complex crime of robbery with homicide.

RULING

Yes, the Supreme Court affirmed the conviction. The prosecution successfully established Fegidero’s guilt through a combination of direct and circumstantial evidence that formed an unbroken chain leading to the inescapable conclusion of his culpability. The eyewitness account of Eddie Mayani, who positively identified Fegidero under sufficient illumination, was credible and consistent. This testimony was corroborated by the events immediately following the crime: Fegidero was seen fleeing with the victim’s bag, which he discarded when chased; the bag was recovered and identified as the victim’s; and a bloodied knife was found in Fegidero’s possession upon arrest.
The Court rejected the defense of denial and alibi, emphasizing that such defenses cannot prevail over positive identification. The victim’s dying declaration, identifying his assailant as the one who held him up, was also admissible as part of the res gestae. All elements of robbery with homicide were present: Fegidero took personal property with intent to gain, employing violence by stabbing the victim, which directly caused the victim’s death on the occasion of the robbery. The penalty of reclusion perpetua was correctly imposed, and the Court affirmed the award of civil indemnity and added moral damages.