G.R. No. L-34290 March 28, 1980
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROBERTO MENDOZA Y CRUZ, accused.

FACTS

On the evening of April 27, 1970, Francisco Garido was driving his jeepney along Taft Avenue in Manila when three men boarded. Shortly after, they announced a holdup, stabbing the driver and passengers while divesting them of their wristwatches and cash. Passenger Oscar Tagudin died from his wounds, while Claro Dabajo and Alicia Victoria sustained serious injuries. Alicia Victoria managed to recover her watch from one assailant during the struggle. The perpetrators then fled. Roberto Mendoza was later charged with robbery with homicide and multiple serious physical injuries as one of the three perpetrators.
At trial, the prosecution relied on the eyewitness Identification of victim Alicia Victoria and driver Francisco Garido. Victoria positively Identified Mendoza in a police lineup over a year after the incident and during trial, noting she remembered his face and long hair as he sat directly across from her in the jeepney. Mendoza interposed an alibi, claiming he was in Bulacan at the time. His attempt to corroborate this through a witness failed, as her testimony was inconsistent and did not support his claim. The trial court convicted Mendoza of robbery with homicide, aggravated by craft and abuse of superiority, and imposed the death penalty.

ISSUE

Was the guilt of accused Roberto Mendoza for the crime of robbery with homicide proven beyond reasonable doubt based on the eyewitness Identification, notwithstanding his defense of alibi?

RULING

Yes, the Supreme Court affirmed the conviction, holding that Mendoza’s guilt was established beyond reasonable doubt. The Court found the positive Identification by eyewitness Alicia Victoria to be credible, convincing, and conclusive. She provided clear and unwavering testimony, detailing her opportunity to observe Mendoza during the incident as he sat directly opposite her in the well-lit jeepney, and she consistently pointed to him in both a pre-trial lineup and in court. The Court emphasized that her positive Identification prevails over Mendoza’s weak alibi, which was uncorroborated and further undermined by his witness’s contradictory statements. The Court also noted the driver’s supporting Identification.
Regarding the penalty, the Court ruled that the crime of robbery with homicide absorbed the other physical injuries inflicted. While the trial court correctly appreciated the aggravating circumstances of craft and abuse of superiority, the death penalty imposed required automatic review. Due to the lack of the requisite number of votes to affirm the capital punishment, the Supreme Court commuted the sentence to reclusion perpetua. The civil liabilities were affirmed with modification, ordering the return of Claro Dabajo’s wristwatch or payment of its value.