G.R. No. L-13974; August 31, 1961
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLANDO DE LA CRUZ, defendant-appellant.

FACTS

The appellant, Rolando de la Cruz, was convicted by the Court of First Instance of Occidental Negros for the complex crime of robbery with homicide concerning the death of Gung Hoc, and for slight physical injuries inflicted upon Maria Tan. The incident occurred on the evening of November 20, 1957, at the victims’ store in Bacolod City. Evidence established that the appellant, wearing a mask, entered the store, struck Gung Hoc on the head with a piece of wood, and took P400 from a showcase. Maria Tan, upon hearing her husband groan, confronted the appellant, grappled with him, and was beaten with the same wooden instrument. Gung Hoc later died from his injuries. Multiple eyewitnesses, including Felisa Tañoan, Maria Sarona, and Abner Absin, identified the appellant as the perpetrator. A critical piece of corroborative evidence was the scar found on the appellant’s breast, consistent with Maria Tan’s testimony that she bit him during the struggle.

ISSUE

The core issue is whether the evidence presented by the prosecution is sufficient to prove beyond reasonable doubt the guilt of the appellant for the crimes of robbery with homicide and slight physical injuries.

RULING

The Supreme Court affirmed the conviction, upholding the trial court’s findings. The legal logic centers on the credibility of witnesses and the corroborative physical evidence. The Court emphasized that the testimonies of the eyewitnesses were consistent, credible, and given by individuals with no motive to falsely testify. The positive identification by Maria Tan, who had a clear view of the appellant after pulling off his mask during their struggle, was deemed highly reliable. The physical evidence—specifically, the scar on the appellant’s breast matching Maria Tan’s account of biting him—provided strong corroboration, creating an unbroken chain of evidence pointing to his guilt. The Court also found no merit in the appellant’s motion for a new trial based on an alleged jailhouse confession from another inmate, as it was unsupported by the requisite affidavits under the Rules of Court. The penalty of reclusion perpetua for robbery with homicide was sustained. The Court modified the judgment by ordering the appellant to return the stolen P400 to Maria Tan, as restitution is a necessary consequence of a robbery conviction. The decision underscores the principle that positive identification by credible witnesses, when corroborated by physical evidence, prevails over denial and alibi.