GR L 33228; (December, 1979) (Digest)
G.R. No. L-33228 December 14, 1979
THE PEOPLE OF THE PHILIPPINES, Plaintiff-appellee, vs. DOMINGO GUEVARRA alias “Enchong Guevarra,” defendant-appellant.
FACTS
On the evening of March 12, 1969, Lorenzo Manuzon was at his home in San Miguel, Bulacan, with his family. He had just given his wife, Honorata Sevilla Manuzon, the day’s earnings of P80.00. Armed men, later identified as co-accused Eduardo Catindihan and Eduardo Duria, entered the house, demanded money, and pushed Honorata towards a bedroom. Catindihan shot her, causing fatal injuries, and then fired repeatedly at Lorenzo, who managed to hide. Another co-accused, Eduardo Agujo, was seen holding one of the Manuzon children at gunpoint. After Catindihan exhausted his ammunition and fled, Lorenzo pursued him to the balcony. At this point, appellant Domingo Guevarra, stationed at the foot of the stairs, fired a Garand rifle at Lorenzo but missed. Honorata, who was pregnant, later died from her gunshot wounds. The robbers escaped with the money.
ISSUE
The core issue is whether the defense of alibi presented by appellant Domingo Guevarra can prevail over his positive identification by the victim, Lorenzo Manuzon, as a participant in the crime of robbery in band with homicide.
RULING
The Supreme Court affirmed the conviction and the imposition of the death penalty. The Court rejected Guevarra’s alibi, which claimed he was elsewhere during the incident, as inherently weak. It was categorically overcome by the positive, clear, and convincing testimony of eyewitness Lorenzo Manuzon, who identified Guevarra as the person who shot at him from the foot of the stairs as he pursued the fleeing Catindihan. The Court emphasized that for alibi to succeed, it must demonstrate the physical impossibility of the accused’s presence at the crime scene, which Guevarra failed to establish.
Furthermore, the Court ruled that conspiracy among the accused was conclusively proven. The collective actions of the group—storming the house, demanding money, shooting the victims, and acting as lookouts—demonstrated a unity of purpose and a concerted design to commit robbery. Guevarra’s specific role as a lookout, culminating in his act of firing at Lorenzo, integrated him into this conspiracy. In law, the act of one conspirator is the act of all, making Guevarra equally liable as a co-principal for the complex crime of robbery with homicide. The Court found no reason to disturb the trial court’s finding of aggravating circumstances—nighttime, band, superior strength, and dwelling—which justified the supreme penalty. The decision was affirmed in toto.