G.R. No. 88324. July 6, 1990.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANGELO ARCEO y MALI, accused-appellant.

FACTS

Accused-appellant Angelo Arceo, together with Ramil Cecilio, was charged with Robbery with Homicide before the Regional Trial Court of Manila. The information alleged that on May 22, 1986, in Manila, they conspired to rob Delfin Manalese of his wristwatch valued at P1,500.00, and on the occasion thereof, stabbed and killed him. The prosecution presented eyewitness Rolando Caladiao, who testified that he saw Arceo and Cecilio approach the victim. Cecilio held the victim from behind while Arceo stabbed him and took his watch. Caladiao positively identified both accused, noting he was about three arm-lengths away and the area was well-lit. The medico-legal officer confirmed the fatal chest wound.
The defense consisted of alibi. Arceo claimed he was in Caloocan City, singing with friends from 7:00 PM to 10:00 PM on the night of the crime, which occurred around 8:00 PM in Manila. He asserted it was impossible to be at the crime scene. The trial court convicted both accused of Robbery with Homicide and sentenced them to reclusion perpetua. Only Arceo appealed.

ISSUE

Whether the trial court erred in convicting accused-appellant Angelo Arceo of Robbery with Homicide based on the eyewitness identification and in rejecting his defense of alibi.

RULING

The Supreme Court affirmed the conviction. The Court held that the positive identification by eyewitness Rolando Caladiao prevails over the weak defense of alibi. Caladiao’s testimony was clear, credible, and consistent. He had a clear view of the incident from a short distance under sufficient lighting and even recognized the accused as persons he had seen loitering in the area before. The Court found no reason to doubt his account, especially as he witnessed the actual stabbing and robbery.
Regarding the defense of alibi, the Court ruled it must be established with clear and convincing evidence that the accused was so far away that he could not have been physically present at the crime scene. Arceo’s claim of being in Caloocan failed this test. He admitted that travel by jeep or taxi from Caloocan to the crime scene in Manila would take only about ten minutes. This did not constitute physical impossibility, making his alibi untenable. Furthermore, the Court found conspiracy. The coordinated acts of Cecilio holding the victim from behind to immobilize him and Arceo stabbing and robbing the victim demonstrated a unity of criminal purpose, making each liable for the acts of the other. The crime was thus properly classified as Robbery with Homicide, a special complex crime under Article 294 of the Revised Penal Code. The penalty of reclusion perpetua was affirmed.