G.R. No. L-24310 October 19, 1976
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TEOFILO ABROGAR alias TEODULO ET AL., defendants, TEOFILO ABROGAR alias TEODULO, CRISPIN TICANO and DANIEL ABROGAR alias QUIEL, defendants-appellants.

FACTS

In the early morning of May 21, 1964, the house of spouses Juan and Emilia Biagtan was robbed. The perpetrators forcibly entered by destroying a panel of the back door, ransacked the home, and carted away cash and valuables amounting to P1,140. During the incident, Juan Biagtan was stabbed nine times, leading to his death. The police investigation led to the identification and arrest of several suspects, including appellants Teofilo Abrogar, Crispin Ticano, and Daniel Abrogar. A co-accused, Mauricio Castro, was discharged from the information to become a state witness.
At trial, Mauricio Castro testified that on the evening of May 20, 1964, he was picked up by Daniel Abrogar and others in a jeep. Daniel informed them they were going to “stage a hold-up.” The group proceeded to a house, where they poisoned a barking dog, scaled a fence, and forced open a door. Castro stayed outside as a lookout. After the robbery, he heard one companion say he had stabbed someone. Later, Teofilo Abrogar gave Castro P45 as his share of the loot. This testimony was corroborated by the affidavit of Teofilo Abrogar and the victims’ identification.

ISSUE

Whether the trial court erred in convicting the appellants based primarily on the uncorroborated testimony of a discharged co-conspirator, Mauricio Castro.

RULING

The Supreme Court affirmed the conviction, holding that the trial court correctly relied on the evidence presented. The legal logic is that the testimony of an accomplice, even if uncorroborated, is sufficient for conviction if it satisfies the court beyond reasonable doubt as to the accused’s guilt. Here, Mauricio Castro’s testimony was not uncorroborated. It was substantially corroborated by the extrajudicial confession of appellant Teofilo Abrogar, which placed Castro and Ticano at the scene of the crime. Furthermore, the testimony of victim Josefina Biagtan positively identified Teofilo Abrogar as one of the robbers who entered her room at gunpoint.
The Court also found the appellants’ defenses of alibi to be weak and unavailing. Alibi is inherently a weak defense and cannot prevail over the positive identification by credible witnesses. The trial court meticulously examined the alibi of Daniel Abrogar, even conducting ocular inspections of the nightclubs he claimed to have been in, but found no corroboration for his whereabouts. The proximity of the appellants’ residences to the crime scene also rendered their alibis physically possible to fabricate. Consequently, the positive testimonies of the prosecution witnesses, taken together, established the appellants’ guilt beyond reasonable doubt for the special complex crime of robbery with homicide. The Court only modified the civil indemnity, increasing it to P12,000 for the death of Juan Biagtan.