G.R. No. 142932 May 29, 2002
People of the Philippines vs. Joel Gonzales and Romeo Bernaldez

FACTS

On July 5, 1992, armed men entered the house of spouses Nicanor and Carolita Suralta in San Isidro, Davao Oriental. One assailant, armed with a gun, wore a bonnet; the other, armed with a knife, wore a handkerchief over his face. They announced a holdup, ordered the occupants into a bedroom, and demanded money and a gun. Carolita surrendered P2,100.00, after which the knife-wielder ransacked the cabinet, taking an additional P325.00, a cassette recorder, and other items. A guest, Arsenio Abonales, was also robbed of his Seiko wristwatch. As the perpetrators fled, gunshots were heard. Nicanor Suralta was found wounded and later died from multiple gunshot wounds.
A subsequent police investigation into a different holdup on July 12, 1992, in a neighboring town led to the apprehension of appellant Joel Gonzales, from whom a handgun and various stolen items, including a cassette recorder, were recovered. On July 14, 1992, Carolita Suralta and Arsenio Abonales were brought to the police station, where they positively identified Gonzales as the gunman and appellant Romeo Bernaldez (Carolita’s nephew) as the knife-wielder, despite the disguises worn during the crime.

ISSUE

Whether the guilt of accused-appellants Joel Gonzales and Romeo Bernaldez for the complex crime of robbery with homicide was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The positive identification by eyewitnesses Carolita Suralta and Arsenio Abonales, who had a clear view of the perpetrators during the well-lit robbery, was categorical and consistent. Their ability to recognize appellants despite the disguises was credible, especially given Carolita’s familial relation to Bernaldez. The Court found no ill motive for the witnesses to falsely testify. The defense of alibi proffered by both appellants was inherently weak and could not prevail over the positive identification. The recovery of stolen items, including the cassette recorder identified by Carolita, from Gonzales further corroborated his participation. The killing of Nicanor Suralta was established to have occurred by reason or on the occasion of the robbery, as the gunshots immediately followed the felons’ departure, satisfying the elements of the complex crime. The trial court’s factual findings on witness credibility are accorded great weight. Thus, the Court upheld the penalty of reclusion perpetua and the awarded civil liabilities.