GR 38434; (December, 1933) (Digest)
G.R. No. 38434 , December 23, 1933
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. MARCIANO MEDINA y DIOKNO (alias MARIANO MEDINA, alias ALEJANDRO DOLA), defendant-appellant.
FACTS
The defendant-appellant, Marciano Medina, was convicted by the Court of First Instance of Manila for the crime of robbery in an inhabited house and for being a habitual delinquent. The information alleged that on February 12, 1932, in Pasay, Rizal, he broke into the house of James C. Rockwell by tearing a window screen and stole personal property valued at P320. The prosecution’s key evidence was a fingerprint found on a small silver box taken from Mrs. Rockwell’s room during the robbery and later found in the garden. A Constabulary fingerprint expert, Agripino Ruiz, testified that this fingerprint matched the fingerprint of the defendant, identifying ten points of similarity. The defendant denied involvement and presented an alibi, claiming he was at home with a sore foot on the night of the robbery, but this testimony was uncorroborated. He also admitted to three prior convictions for theft.
ISSUE
Whether the trial court erred in convicting the defendant based on the fingerprint evidence and in finding him guilty of robbery and as a habitual delinquent.
RULING
No, the trial court did not err. The Supreme Court affirmed the conviction but modified the penalties. The Court held that fingerprint evidence is admissible and reliable for proving identity, citing scientific authority and judicial precedents. The testimony of the fingerprint expert, whose qualifications were admitted by the defense, was deemed credible and sufficient to establish that the fingerprint on the stolen box was that of the defendant. The defendant’s uncorroborated alibi could not prevail over this positive identification, especially considering his criminal record as a recidivist. On the penalties, the Court reduced the principal penalty for robbery to six years and one day of prision mayor, considering the aggravating circumstances of recidivism and nocturnity. The additional penalty for habitual delinquency was also reduced to six years and one day. The decision of the lower court was affirmed with these modifications.
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