G.R. No. 252212 , July 14, 2021
People of the Philippines, Plaintiff-Appellee, vs. Roberto G. Campos, Accused-Appellant.

FACTS

On April 20, 2003, at about 8:00 p.m., Emeliza P. Empon was inside her house in Antipolo City with her boyfriend Eric Sagun and neighbor Marilou Zafranco-Rea. An armed man suddenly barged in, took Emeliza’s cellphone from the living room table, pointed a gun at her, and shot her in the chest, causing her death, before fleeing. Eric and Marilou immediately reported the incident to the police, describing the suspect as “[m]edyo malaki katawan.” Acting on information that the suspect was seen in Pasig City, police officers proceeded there, saw a man matching the description who attempted to run, arrested him, and recovered a .38 caliber firearm. The arrested man was accused-appellant Roberto G. Campos. At around 3:00 a.m. the following day, Eric and Marilou positively identified Roberto in a police lineup as the perpetrator. Roberto was charged with Robbery with Homicide. He pleaded not guilty, claiming he was at a friend’s house in Pasig City when police arrested him at midnight, placed a plastic bag on his head, punched him, and forced him to confess. The Regional Trial Court convicted Roberto, a decision affirmed by the Court of Appeals. Roberto appealed, questioning the out-of-court identification, the witnesses’ credibility, the lack of paraffin test results, and the rejection of his alibi.

ISSUE

The core issue is the validity and reliability of the out-of-court identification made by eyewitnesses Eric Sagun and Marilou Zafranco-Rea during a police lineup, and whether such identification, along with the totality of evidence, proves Roberto’s guilt for Robbery with Homicide beyond reasonable doubt.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that the out-of-court identification of Roberto was valid and reliable under the totality of circumstances test, considering: (1) the witnesses had a good view of the gunman at close proximity; (2) they exhibited a high degree of attention with no competing distractions; (3) their prior description of the suspect’s build, though generic, matched Roberto’s physique and discrepancies are allowed; (4) the identification occurred only seven hours after the crime, a short lapse; (5) the witnesses demonstrated a high level of certainty in their identification; and (6) there was no evidence of suggestiveness in the police lineup procedure. The positive identification prevails over Roberto’s uncorroborated alibi and denial. The Court also ruled that the failure to present paraffin test results does not constitute reasonable doubt, as such tests are not conclusive evidence. The award of damages was modified in accordance with prevailing jurisprudence.