GR 135682; (March, 2003) (Digest)
G.R. No. 135682 ; March 26, 2003
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO REYES y BATAC, accused-appellant.
FACTS
The prosecution’s case, primarily through the testimony of PO1 Eduardo Molato, established that on October 12, 1997, at 2:00 a.m., PO1 Molato witnessed two men hold up and stab the victim, Donaldo Salmorin, Jr., at a street corner in Navotas. Molato, who was about 8 to 10 meters away, saw one assailant forcibly take the victim’s wristwatch while the other stabbed him. He fired a warning shot and gave chase but eventually lost the suspects after securing aid for the victim. He positively identified accused-appellant Danilo Reyes as the one who stabbed the victim.
Accused-appellant denied involvement, claiming he was asleep at home at the time of the incident and was later arrested for a different offense. He asserted he was mistakenly identified due to sharing the alias “Buboy Nguso” and similar physical features with his co-accused, Arnel Cergantes, who remained at large. The Regional Trial Court convicted Reyes of Robbery with Homicide and sentenced him to reclusion perpetua, ordering him to pay indemnity and damages.
ISSUE
Whether the prosecution proved the guilt of accused-appellant Danilo Reyes for the crime of Robbery with Homicide beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court meticulously applied the elements of Robbery with Homicide: (a) taking of personal property with violence or intimidation; (b) the property belongs to another; (c) the taking is done with intent to gain (animus lucrandi); and (d) homicide is committed by reason or on the occasion of the robbery. The Court found all elements present. The eyewitness account of PO1 Molato detailed the forcible taking of the victim’s wristwatch immediately before the stabbing, proving the intent to gain and that the homicide was integral to the robbery. The claim that the taking was a mere afterthought was rejected, as the sequence of events showed a unified criminal purpose.
Regarding identification, the Court upheld the trial court’s assessment of PO1 Molato’s credibility. His testimony was clear, positive, and consistent, made from a sufficient distance under adequate lighting, and he had no ill motive to falsely testify. The defense of alibi and denial, being inherently weak, could not prevail over this credible positive identification. The Court also clarified that the prosecution’s discretion in presenting witnesses is not subject to the accused’s demand, and a conviction can rest on the testimony of a single credible witness. The awarded civil liabilities were affirmed as consistent with prevailing jurisprudence.