GR 94127; (July, 1991) (Digest)
G.R. No. 94127 ; July 1, 1991
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. HERMAN RECEPTION and WILLIAM RECEPTION, defendants-appellants.
FACTS
The prosecution evidence established that on September 8, 1989, appellants Herman and William Reception, armed with short firearms and wearing fatigue uniforms, entered the house of spouses Mario and Leticia Baiza in Sitio Toong, Magsaysay, Occidental Mindoro. After herding the family inside, they demanded firearms, ransacked the house, and stole cash and items valued at P11,600.00. William then struck Mario on the head with a gun. The appellants took the Baizas’ son, Edgardo, outside under the pretense of bringing him to a barracks. Shortly after, a gunshot was heard. When Mario and Leticia rushed to the scene, they found Edgardo lying bloodied and were themselves shot by the still-concealed assailants, whose voices they recognized. Edgardo died from his wounds, while the spouses survived after medical treatment.
The appellants interposed the defense of alibi, claiming they were attending a birthday celebration for their niece at a house roughly 500 meters away during the entire evening. They presented witnesses who testified to seeing them at the party. The trial court rejected this defense, convicted the appellants of Robbery with Homicide, and sentenced each to reclusion perpetua.
ISSUE
Whether the trial court erred in convicting the appellants based on the identification by the prosecution witnesses and in rejecting their defense of alibi.
RULING
The Supreme Court affirmed the conviction. The positive identification of the appellants by the victims, Mario and Leticia Baiza, who had sufficient opportunity to observe them during the prolonged incident inside their well-lit house, prevails over the weak defense of alibi. The relationship of the witnesses to the victim does not impair their credibility absent evidence of improper motive, and no such motive was shown here. For alibi to prosper, it must be demonstrated that the accused could not have been physically present at the crime scene at the time of its commission. The appellants failed this test, as the distance of 500 meters between the party and the crime scene was not an insurmountable barrier; they could have easily slipped away and returned without being noticed amidst the party’s revelry. The Court found the alibi contrived and contrary to common experience. The crime of Robbery with Homicide was thus proven beyond reasonable doubt. The Court modified the civil indemnity, increasing the award for Edgardo Baiza’s death from P30,000.00 to P50,000.00 in accordance with prevailing jurisprudence.