G.R. No. 114388 March 12, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOMINGO TRILLES, SILVESTRE TRILLES, IGMIDIO BIBLIAÑAS and EPITACIO RIOFRIR, JR., accused-appellants.
FACTS
On January 5, 1991, in Barangay San Jose, Oas, Albay, Vicente Rellama was killed in his home. Prosecution eyewitnesses Felix Repia and Leopoldo Balde testified that they saw the four appellants inside the victim’s house. They witnessed appellant Domingo Trilles demand money from Vicente and, upon the victim’s refusal, order his brother Silvestre to forcibly open a wooden trunk. When Vicente tried to grab a brown bag retrieved from the trunk, Domingo hacked him. All four appellants then ganged up on Vicente, delivering multiple hacking blows. The appellants fled after taking cash and various personal properties. The witnesses immediately reported the crime, and a necropsy confirmed Vicente died from multiple hack wounds.
At trial, each appellant invoked alibi. Domingo Trilles, a CAFGU member, claimed he was confined to his detachment camp due to a red alert. Igmidio Bibliañas asserted he was attending a wedding celebration. Silvestre Trilles and Epitacio Riofrir, Jr. both claimed to have been at their respective homes. The Regional Trial Court convicted all appellants of the complex crime of Robbery with Homicide and sentenced them to reclusion perpetua.
ISSUE
Whether the guilt of the appellants for the crime of Robbery with Homicide was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimonies of eyewitnesses Felix Repia and Leopoldo Balde to be credible, positive, and consistent. Their account of the robbery and the collective hacking of the victim was clear and convincing. The Court rejected the appellants’ defenses of alibi and denial, which are inherently weak. For alibi to prosper, the accused must prove it was physically impossible for them to be at the crime scene. The evidence showed the appellants’ alleged locations were all within a one-kilometer radius of the victim’s house, a distance easily negotiable on foot. Thus, they failed to demonstrate physical impossibility.
The appellants’ collective presence and actions—demanding money, breaking open a trunk, and simultaneously attacking the victim—established conspiracy. Their collective purpose to rob was evident, and the killing was perpetrated on the occasion thereof, satisfying the elements of Robbery with Homicide under Article 294(1) of the Revised Penal Code. The penalty of reclusion perpetua was affirmed. However, the civil indemnity awarded to the victim’s heirs was reduced from P80,000 to P50,000, consistent with prevailing jurisprudence at the time. No evidence was presented to prove the exact value of the stolen items, so no other reparation could be ordered.
