G.R. No. L-34250 & L-34249, May 3, 1983
The People of the Philippines, plaintiff-appellee, vs. Luis Trinidad y Victorino and Juan Barros y Dayap, defendants-appellants.

FACTS

On December 4, 1970, in Manila, appellants Juan Barros and Luis Trinidad, conspiring with others, staged a robbery. The victims were bank messengers from Citizen’s Bank traveling in a jeep. While stopped at an intersection, the appellants, using armalite rifles and a pistol, opened fire. Bank messengers Carlito Cardenio and Aurelio Navarro were killed, and security guard Francisco Casio, Jr. sustained serious injuries. The appellants took a portfolio containing cash and checks. The accused were charged with Robbery with Homicide and Serious Physical Injuries. After a joint trial, the Circuit Criminal Court of Manila found them guilty and imposed the death penalty.
The defense of both appellants was alibi. Barros claimed he was at a police precinct at the time, presenting police blotter entries and statements. Trinidad claimed he was at a construction site. The trial court rejected these defenses, finding the prosecution witnesses, particularly the injured guard Casio, to be credible. The court noted the inherent weakness of alibi and the ease with which the presented police records could be fabricated or altered. Trinidad subsequently escaped from prison during the appeal.

ISSUE

Whether the trial court erred in convicting the appellants of Robbery with Homicide and Serious Physical Injuries and in imposing the death penalty.

RULING

The Supreme Court affirmed the conviction and the imposition of the death penalty. The Court upheld the trial court’s assessment of the credibility of the eyewitness testimony, which positively identified the appellants as the perpetrators. The defense of alibi was correctly dismissed as it could not prevail over the positive identification by credible witnesses. The Court found the collective testimonies of the prosecution witnesses to be consistent and reliable, establishing the elements of the crime beyond reasonable doubt.
Regarding the penalty, the crime of Robbery with Homicide under Article 294(1) of the Revised Penal Code is punishable by reclusion perpetua to death. The Supreme Court, in a per curiam decision, sustained the finding of the presence of aggravating circumstances—specifically, treachery, use of a motor vehicle, and band—with no mitigating circumstances to offset them. This justified the imposition of the capital penalty. The Court also affirmed the awards for civil indemnity, moral and exemplary damages, and restitution. One Justice voted for reclusion perpetua, but the majority affirmed the death sentence.