G.R. No. 91694 March 14, 1997
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SABAS CALVO, JR., and RODOLFO LONGCOP, accused-appellants.

FACTS

The case involves the robbery with homicide of Ignacia Mauleon on September 26, 1987, at her bakery in Manila. Prosecution evidence established that two men were seen fleeing the crime scene. Beatriz Bido, a salesgirl, witnessed appellant Sabas Calvo, Jr. and another man, Bobby Gaspar, forcibly exit Mauleon’s room; Calvo was armed and threatened Bido. She later found Mauleon dead inside the ransacked room. Lucila Gorospe, a nearby store owner, also saw two men running from the bakery, identifying one as Calvo, who was carrying a bag. The police investigation led to Calvo’s eventual arrest in Northern Samar.
The defense presented alibi, claiming Calvo was elsewhere during the incident. The trial court convicted Calvo of robbery with homicide, sentencing him to reclusion perpetua, which it equated with life imprisonment in the dispositive portion of its decision. Calvo appealed, challenging the credibility of the eyewitness identifications and the sufficiency of the evidence.

ISSUE

The core issue is whether the prosecution proved the guilt of appellant Sabas Calvo, Jr. for the crime of robbery with homicide beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but corrected a penalty error. The Court upheld the trial court’s assessment of witness credibility. Both Bido and Gorospe provided clear, positive, and consistent identifications of Calvo fleeing the scene. Their testimonies were deemed credible, as they had no ill motive to falsely testify, and their opportunity to observe was established—Bido faced Calvo at close range under threat, and Gorospe had a well-lit view from her store. The Court reiterated the doctrine that alibi and denial cannot prevail over positive identification, especially when the alibi is not physically impossible. The evidence sufficiently established conspiracy, as the collective actions of the accused showed a common purpose to commit robbery, resulting in homicide.
However, the Court modified the penalty. The trial court correctly imposed reclusion perpetua under Article 294 of the Revised Penal Code but erroneously referred to it as “life imprisonment.” The Court clarified these are distinct penalties; reclusion perpetua is a specific penalty under the Revised Penal Code with a definite duration and accessory penalties, whereas life imprisonment is prescribed by special laws. Thus, the dispositive portion was amended to remove the reference to “life imprisonment,” affirming the penalty of reclusion perpetua in its proper legal sense.