G.R. No. 123054; June 10, 2003
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. FAUSTO OBEDO y BORBAJO alias “TITING”, Accused-Appellant.

FACTS

On February 21, 1990, spouses Wilfredo and Jinky Luayon were robbed and killed in their home in Kapalong, Davao. The prosecution evidence established that appellant Fausto Obedo, together with Arnold Ranalan and Tony Villamor, went to the victims’ house that evening. Jesus Saraga testified he escorted the three men near the house and saw Ranalan with a gun. Dominador Luayon, the victim’s brother, heard a commotion and gunshots from the nearby house. He saw appellant and Ranalan jump out of a broken window. Upon entering, he found the spouses fatally shot and a chest ajar with items scattered. Dionisio Luayon testified that the dying Jinky whispered they were robbed by appellant and Ranalan. Investigation revealed the victims had a significant amount of cash from a recent palay sale.
The defense presented alibi and denial. Appellant claimed he was in a different barangay for business and was at home the entire evening of the crime. He asserted he was arrested without a warrant and that the prosecution witnesses were motivated by ill will.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that appellant is guilty of the complex crime of robbery with homicide.

RULING

The Supreme Court affirmed the conviction. The prosecution successfully established all elements of robbery with homicide: (1) the taking of personal property with violence or intimidation; (2) the property belongs to another; (3) the taking is with animo lucrandi; and (4) on the occasion of the robbery, homicide is committed. The taking was proven by the testimony on the ransacked chest and the missing cash from the palay sale. The homicide was established by the medical certificates and eyewitness accounts of the deaths.
The Court found the testimonies of prosecution witnesses credible, consistent, and corroborative. The dying declaration of Jinky Luayon, identifying appellant as one of the robbers, carries significant weight. Appellant’s defenses of alibi and denial cannot prevail over the positive identification by witnesses. Alibi is inherently weak and requires proof of physical impossibility to be at the crime scene, which appellant failed to demonstrate. The claim of improper motive by witnesses was unsubstantiated. The collective weight of the evidence—eyewitness account, dying declaration, and circumstantial evidence (e.g., appellant’s companion borrowing a bloodied shirt)—formed an unbroken chain leading to the conclusion of appellant’s guilt beyond reasonable doubt. The penalty of reclusion perpetua and awarded damages were sustained.