GR 173876; (June, 2008) (Digest)
G.R. No. 173876 ; June 27, 2008
VALCESAR ESTIOCA y MACAMAY, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.
FACTS
Petitioner Valcesar Estioca, along with three others, was charged with robbery for forcibly entering a classroom at Ozamiz City Central School on July 28, 2001, and stealing a television, a karaoke player, and an electric fan valued at P15,000. The prosecution’s primary witness was Nico Alforque, an 11-year-old student who testified that he saw Estioca and a co-accused climb the school gate, destroy a padlock with an iron bar, enter the classroom, and carry the items out to waiting accomplices. The defense, consisting of Estioca and his co-accused, denied involvement and presented alibis. Estioca specifically claimed he was at home and later at a friend’s house during the incident. He further alleged that his extrajudicial confession was extracted through torture, including beatings and burns.
ISSUE
The core issue is whether the prosecution proved Estioca’s guilt for the crime of robbery beyond reasonable doubt, particularly in light of the defense of alibi and the challenge to the credibility of the child witness.
RULING
The Supreme Court affirmed the conviction. The Court upheld the credibility of Nico Alforque’s positive identification. As an eyewitness, his detailed account of the robberyβincluding how the accused entered, the tools used, the items taken, and their escapeβwas found clear, consistent, and credible. The Court emphasized that the testimony of a single credible witness is sufficient for a conviction. Estioca’s defense of alibi was correctly rejected by the lower courts as inherently weak and unsubstantiated by clear and convincing proof that it was physically impossible for him to be at the crime scene. His claim of torture to invalidate his confession was immaterial, as the trial court did not rely on any extrajudicial statement for the conviction. The conviction was based squarely on Nico’s credible eyewitness testimony, which established all the elements of robbery under Article 299(a)(2) of the Revised Penal Code: unlawful taking with intent to gain, through the use of force upon things (breaking the padlock). The penalty and civil liability were also affirmed.
