G.R. No. 87959 August 13, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARCELINO C. MANDAL, EDUARDO P. MANANSALA, AND JOHN DOE, accused, MARCELINO C. MANDAL AND EDUARDO P. MANANSALA, accused-appellants.

FACTS

The prosecution established that in the early morning of July 4, 1986, Sergeants Thomas Sessamen and Gavino Jose Mendez, both USAF personnel, boarded a jeepney in Angeles City. The driver was accused Eduardo Manansala. Instead of proceeding to the victims’ destination, Manansala drove to a dark, isolated street. Inside the jeepney, accused Marcelino Mandal, seated in front of Mendez, grabbed Mendez, poked a knife at his neck, and demanded his valuables. A struggle ensued. Mendez eventually jumped from the moving vehicle but was stabbed in the back by Mandal. Mendez survived, sought help, and was hospitalized. Sgt. Sessamen was found dead on the same road later that morning, having sustained six stab wounds. Mendez later positively identified both accused in separate police line-ups, noting Mandal’s distinctive “S” tattoo between his thumb and forefinger.
The accused interposed the defense of alibi. Mandal claimed he was with his girlfriend in San Ignacio, Angeles City, from the evening of July 3 until the morning of July 4. The trial court convicted both accused of Robbery with Homicide and sentenced them to life imprisonment. They appealed, challenging the identification and the rejection of Mandal’s alibi.

ISSUE

Whether the trial court erred in convicting the accused-appellants based on the victim’s identification and in rejecting the defense of alibi.

RULING

The Supreme Court affirmed the conviction, modifying the penalty to reclusion perpetua. The Court upheld the positive identification by Sgt. Mendez as credible and reliable. Mendez had a clear view of Mandal inside the well-lighted jeepney when he was robbed and saw his tattoo. He also identified Manansala as the driver who deliberately diverted the route. These identifications were reinforced during police line-ups and in open court. The Court emphasized that the defense failed to impute any ill motive on Mendez, whose testimony was straightforward and based on personal knowledge.
Regarding the alibi, the Court ruled it cannot prevail over positive identification. For alibi to succeed, the accused must demonstrate it was physically impossible to be at the crime scene. Mandal himself admitted that travel from his claimed location to the crime scene in Pulong-Maragul took only four to five minutes, negating any impossibility. The collective actions of the accused—Manansala driving to an isolated area and Mandal directly assaulting the victims—proved conspiracy in committing Robbery with Homicide. Thus, no reasonable doubt existed to warrant acquittal.