G.R. No. 95539 June 14, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MELCHOR DATINGGINOO y BRIONES, accused-appellant.

FACTS

On September 5, 1988, at about 8:15 p.m., Mariano Aumentado was on his way home from his drug store in Kalookan City. Three persons accosted him, forcibly took his wallet containing P4,100.00 and a wrist watch worth P750.00, boxed him in the stomach, and stabbed him several times in the chest. He was declared dead on arrival at the hospital. An information for robbery with homicide was filed against Melchor Datingginoo and his unknown companions. During the trial, the prosecution presented two eyewitnesses, Anna Marie Aumentado (the victim’s daughter) and Natividad Raulo vda. de Calayag, who both identified the appellant as one of the assailants, having seen the incident from the drug store which was only six arms length away from the crime scene. They testified that the area was well-lit by lights from houses, stores, and a nearby carnival. The defense presented an alibi, with the appellant claiming he was at the house of his compadre, Antonio Esternon, having a drinking session at the time of the incident. Esternon corroborated this, and another defense witness, Ligaya Alcopra, claimed the appellant was not among the assailants she saw. The Regional Trial Court found the accused guilty beyond reasonable doubt of robbery with homicide and sentenced him to Reclusion Perpetua, with orders for restitution and indemnity.

ISSUE

The main issue is the credibility of the prosecution witnesses versus the defense’s alibi, and whether the trial court correctly convicted the appellant of the special complex crime of robbery with homicide.

RULING

The Supreme Court DISMISSED the appeal and AFFIRMED the appealed judgment with modification. The Court upheld the trial court’s assessment of the credibility of the prosecution witnesses, noting that the conclusions of the trial court on witness credibility are nearly conclusive on appeal. The minor inconsistencies in the eyewitnesses’ testimonies did not destroy their credibility but enhanced it by erasing suspicion of a rehearsed testimony. The appellant’s alibi was deemed weak and unconvincing, as it was not physically impossible for him to be at the crime scene, and it was corroborated only by a friend. The Court found no reason for the prosecution witnesses to falsely implicate the appellant. The elements of robbery with homicide were established, as the original criminal design was robbery and the homicide was perpetrated on the occasion thereof, attended by the aggravating circumstance of abuse of superior strength. The civil indemnity for the victim’s death was increased to P50,000.00 in conformity with existing policy.