G.R. No. 157669 ; April 14, 2004
People of the Philippines, appellee, vs. Juan Alcantara and one alias Aying, accused, Juan Alcantara, appellant.

FACTS

In the early morning of March 7, 1998, at the Bankerohan market in Davao City, appellant Juan Alcantara and an unidentified companion, alias Aying, were charged with robbery with homicide. The prosecution’s lone eyewitness, Leonila Quimada, testified that she saw appellant, from an arm’s length away, try to take the waist bag of the sleeping victim, Liza Cabaral. When Liza resisted, appellant stabbed her on the thigh and then fatally on the chest. Appellant fled, leaving the bag, but Aying took Liza’s wristwatch before escaping. Liza died at the hospital.
The defense presented an alibi, with a former barangay captain testifying that appellant was at a political meeting and subsequent gathering until about 3:00 a.m. on the day of the crime. Defense counsel also testified that Leonila, upon visiting appellant in jail, appeared surprised and allegedly admitted appellant was not the person she had in mind, though she later refused to sign a supplemental affidavit to that effect. The police blotter initially described the perpetrator as an unidentified male.

ISSUE

The core issue is whether the prosecution proved appellant’s guilt for robbery with homicide beyond reasonable doubt, particularly in light of the defense of alibi and alleged inconsistencies in the eyewitness identification.

RULING

The Supreme Court affirmed the conviction. The defense of alibi must fail as it was not physically impossible for appellant to have been at the crime scene, given that the meeting ended around 3:00 a.m. and the incident occurred in the early morning at a location not proven to be an insurmountable distance away. The positive identification by eyewitness Leonila Quimada prevails over the weak alibi. The Court found her testimony credible, straightforward, and consistent on material points. Her familiarity with appellant, having known him for six years from the same market, strengthened her identification.
Minor inconsistencies, such as the initial police blotter entry or her supplemental affidavit implicating another person, do not undermine her core testimony. The Court ruled that such details are common for witnesses in a state of shock and do not affect the essential fact of her eyewitness account. The taking of the wristwatch by Aying after the stabbing constituted robbery, and the killing occurred by reason or on occasion of the robbery, satisfying the elements of the complex crime. The penalty of reclusion perpetua was affirmed, and the awards for civil indemnity, actual, and moral damages were modified accordingly.