G.R. No. 121532 September 7, 1998
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMMEL LACATAN, RUBY VILLAMARIN, and DOMINADOR SALAZAR, accused-appellants.

FACTS

On the evening of November 23, 1990, in Barangay G. Antonio, Gloria, Oriental Mindoro, accused-appellants Rommel Lacatan, Ruby Villamarin, and Dominador Salazar were charged with Robbery with Homicide. The information alleged that, armed with a bladed instrument and acting in concert, they robbed the house and store of Alfredo Salazar, taking cash, jewelry, and foodstuffs valued at P170,000.00. On the occasion of the robbery, they killed Alfredo Salazar by stabbing him multiple times. The prosecution presented eyewitness Eduardo Ruallo, who testified that he went to the victim’s house to borrow money and, upon hearing a commotion, peeped through a window. He saw Villamarin and Dominador Salazar holding the victim’s arms while Lacatan stabbed him repeatedly. The victim’s children, Elmer and Edna Salazar, discovered the crime scene—their father dead in the bathroom and the house ransacked. Anicia Salazar, the widow, testified on the stolen items and funeral expenses. Dr. Edgardo Hernandez, the medico-legal officer, reported the victim suffered nine stab wounds and five incise wounds. The defense relied on alibi and denial, with appellants claiming they were elsewhere (plowing fields, constructing a house, or drinking) during the incident, and presented witnesses who claimed Ruallo was drinking with them at the time. The Regional Trial Court found the accused guilty beyond reasonable doubt and sentenced each to reclusion perpetua, with indemnity and damages.

ISSUE

Whether the trial court erred in convicting the accused-appellants of Robbery with Homicide based on the credibility of the prosecution witnesses, particularly the eyewitness testimony of Eduardo Ruallo, and in rejecting the defense of alibi.

RULING

The Supreme Court affirmed the trial court’s decision. The Court upheld the credibility of eyewitness Eduardo Ruallo, noting the trial court’s superior position to assess witness demeanor and finding no ill motive for Ruallo to falsely testify against the appellants, who were his community neighbors. The defense of alibi was rejected as it could not prevail over Ruallo’s positive identification. The appellants failed to prove it was physically impossible for them to be at the crime scene, as their residences were within 100 meters to 1 kilometer from the victim’s house. The Court found the elements of Robbery with Homicide established: the taking of personal property with violence or intimidation, on the occasion of which homicide was committed. The penalty of reclusion perpetua and the awarded damages were sustained.