GR 127841; (June, 2000) (Digest)
G.R. No. 127841 ; June 16, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EPIE ARLALEJO y CAPUCANAN, accused-appellant.
FACTS
The case involves the robbery of the house of spouses Emiliano and Bernardita Manongas and the killing of Simplicio Manongas on February 12, 1995. The prosecution alleged that appellant Epie Arlalejo, along with Jerry Albasin and a John Doe, conspired to commit the crime. The spouses testified that after Albasin asked for a light, Arlalejo and Doe forcibly entered, announced the robbery, and took P700.00. While leaving, they saw Simplicio sleeping on the porch, took him, and stabbed him to death. The spouses escaped and reported the incident the next day. They claimed to have recognized the accused during the incident.
The defense interposed alibi and denial. Arlalejo claimed he was watching films at a neighbor’s house at the time of the crime. He and Albasin further asserted that they only learned of the incident the next day and, as members of a community organization, even assisted in preparing Simplicio’s body for burial. They were arrested days later.
ISSUE
Whether the guilt of appellant Epie Arlalejo for the special complex crime of robbery with homicide was proven beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted the appellant. The Court emphasized that while alibi is inherently weak, it gains strength when the prosecution’s evidence of identification is insufficient. In this case, the prosecution failed to establish the identity of the appellant as one of the perpetrators beyond reasonable doubt. The Court noted several critical lapses: the victims, who knew the appellant as a resident of a nearby barangay, delayed for four days before causing his arrest, and the circumstances surrounding his identification by the spouses before the police were not presented in evidence. This unrebutted delay and the lack of a clear, immediate identification procedure created reasonable doubt. The prosecution’s evidence, therefore, did not overcome the constitutional presumption of innocence. Consequently, the Court ordered the appellant’s immediate release.