GR L 37146; (March, 1984) (Digest)
G.R. No. L-37146. March 5, 1984.
THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. EDWARD VALENZUELA, Defendant-Appellant.
FACTS
On the evening of October 13, 1970, three armed men, including appellant Edward Valenzuela and co-accused Manolo Padilla, entered the C and A Grocery in Quezon City. They announced a hold-up, ordered owner Alfonso Chua to lie down, and began ransacking the store. During the commotion, Padilla shot and killed Chua’s daughter, Maria Cristina. Valenzuela pistol-whipped Alfonso’s sister-in-law, Bella Bautista, causing her to black out. The robbers fled with cash and cigarettes. The victims later positively identified Valenzuela and Padilla in a police line-up.
Valenzuela interposed the defense of alibi, claiming he was at a political campaign house in Marikina at the time of the crime and did not return home until past 10:00 PM. The trial court convicted him of robbery with homicide and sentenced him to reclusion perpetua. He appealed, challenging the credibility of the witnesses’ identification and the sufficiency of evidence to prove conspiracy.
ISSUE
Whether the trial court erred in convicting appellant Edward Valenzuela of robbery with homicide based on the witnesses’ identification and the finding of conspiracy.
RULING
The Supreme Court affirmed the conviction. The positive identification by multiple eyewitnesses (Alfonso Chua, his wife Remedios, and Bella Bautista) prevails over the weak defense of alibi. The witnesses had sufficient opportunity to observe the appellant during the robbery before being ordered down or attacked. Their identification during a properly conducted police line-up, where Valenzuela was made to change clothes, was reliable. The Court found conspiracy was established by the appellant’s collective and coordinated actions with his co-accused. They arrived together, simultaneously employed arms to intimidate the victims, divested the store of property, and fled together after the shooting. The sworn statements of the accused, which were interlocking, further evidenced their common criminal purpose. Consequently, as a conspirator, Valenzuela is equally liable for the homicide committed during the robbery. The penalty of reclusion perpetua was affirmed, but his civil liability for indemnity was modified to be joint and several with his co-accused.