G.R. No. L-16985; June 29, 1963
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AQUILINO AGUILAR, ET AL., defendants-appellants.

FACTS

In the early morning of March 21, 1958, spouses Sulpicio and Concesa Olario were awakened in their home in Medina, Misamis Oriental, by three intruders. The house was illuminated by two lamps. Concesa positively identified one assailant as Aquilino Aguilar, a known friend of her father. The two others were masked. Aquilino demanded money, and Sulpicio indicated a drawer containing thirty pesos. The spouses were forced to lie face down. Concesa, after being struck with a chair, heard a gunshot. She escaped and later found her husband dead from multiple gunshot wounds. The money was missing. Concesa immediately reported to arriving police that she recognized Aguilar and described his companions.
The appellants—Aquilino Aguilar, Esteban Pacudan, and Pedrito Aguilar—raised alibis. Aquilino and his son Pedrito claimed to have been at their home, a claim supported by a visitor, Francisca Quesaba, whose testimony was riddled with inconsistencies. Esteban Pacudan asserted he was in a different municipality. The defense presented other witnesses, like employer Juana Isobel for Pedrito, but their testimonies were weakened by improbable details and contradictory evidence, such as a power of attorney suggesting another person managed the property where Pedrito allegedly worked.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellants beyond reasonable doubt, overcoming their defenses of alibi and denial.

RULING

The Supreme Court affirmed the convictions but modified the penalties. The positive identification by Concesa Olario, who knew Aquilino Aguilar well and had sufficient light to see him, was deemed credible and compelling. Her immediate report to the police bolstered her reliability. The Court found the alibis unpersuasive. For Aquilino and Pedrito, the supporting testimony of Francisca Quesaba was rejected due to material inconsistencies between her statements in court and before the justice of the peace. For Esteban Pacudan, his alibi failed to prove the physical impossibility of his presence at the crime scene. The collective weakness of the alibis, contrasted with the strong eyewitness account, led the Court to conclude the appellants’ guilt was established.
Regarding penalty, the Court found the aggravating circumstances of nighttime and dwelling were present and not offset by any mitigating circumstance for Aquilino Aguilar and Esteban Pacudan. Consequently, the penalty for robbery with homicide was raised from life imprisonment to death. For Pedrito Aguilar, who was a minor at the time of the crime, the indeterminate sentence imposed by the trial court was upheld as within legal limits. The indemnity to the heirs was affirmed.