G.R. No. L-930; August 29, 1947
THE PEOPLE OF THE PHILIPPINES, plaintiff and appellee, vs. VIVENCIO VICTORIA, ET AL., defendants. PONCIANO DE LA CRUZ, appellant.

FACTS

On the evening of April 28, 1946, several armed men broke into the house of Hermenegildo Maneja in Quezon City. The robbers, armed with pistols and carbines, ordered the occupants to lie face down on the floor. While some searched for money and valuables, others stood guard. When Hermenegildo Maneja realized the robbers intended to take all their money, he urged the other men to fight. Hermenegildo, his brother Gregorio Maneja, and brother-in-law Severino Flores rushed at the robbers, causing them to flee. The robbers were pursued to the stairway. After crossing the fence, the malefactors fired shots back into the house, killing Telesforo Agulay. The robbers succeeded in taking P140 in cash, a wristwatch, and a pair of slippers. Four of the seven charged individuals—Vivencio Victoria, Ponciano de la Cruz, Jesus Beltran, and Leonardo Simbulan—were tried. The trial court found them guilty as co-principals of robbery in band in an inhabited house with homicide. The three younger accused were committed to a reformatory school, while appellant Ponciano de la Cruz, aged 24, was sentenced to reclusion perpetua and ordered to pay indemnities. Only Ponciano de la Cruz appealed.

ISSUE

The main issue is the identity of the appellant, Ponciano de la Cruz, as one of the perpetrators of the crime.

RULING

The Supreme Court affirmed the conviction. The Court found the appellant’s identity as one of the robbers was established beyond doubt. The evidence showed: (1) the house was well-lit by a bright electric light during the robbery; (2) the appellant and his co-accused lived in the neighborhood and were known to the victim, Hermenegildo Maneja, since 1937; (3) Hermenegildo Maneja testified he came face-to-face with and talked to the robbers, and specifically identified the appellant as one of the men who opened a wardrobe and took money; (4) Gregorio Maneja testified the appellant was armed with a .45 caliber pistol and entered his room; (5) two co-accused pointed to the appellant as a confederate in his presence at police headquarters, to which he did not protest; and (6) the appellant’s own statement to the police contained incriminating details. The Court rejected the appellant’s alibi defense as uncorroborated and weak, and found the denials by his co-accused at trial to be unreliable, likely a last-minute attempt to save the adult appellant from a severe sentence. The Court also found no merit in the defense’s claim of “manifest improbability” in the prosecution’s testimony, attributing the robbers’ lack of disguise and the victims’ resistance to the youth and inexperience of the accused. The conviction was affirmed in all respects.