Facts:
In
People of the Philippines v. Edwin Aleman y Longhas, the accused-appellant
Edwin Aleman was charged by Information with committing
robbery with homicide on February 10, 2003 in Quezon City when, together with an unidentified companion, he allegedly approached and ordered the victim,
Ramon Jaime Birosel, to open his car, stabbed him repeatedly with a bladed weapon causing mortal wounds to the chest and heart, and took the victim’s personal effects including two cellular phones, a wallet, cash, a necklace and a ring. The prosecution offered the eyewitness testimony of
Mark Almodovar, a fourteen-year-old deaf-mute who, with the assistance of licensed sign language interpreter Daniel Catinguil, identified accused-appellant in open court as the person who stabbed the victim, described the positions of the assailants and recounted how the two men buried the knife and discarded bloodstained clothing; the medico-legal report by P/S Insp. Elizardo Daileg established the cause of death as hemorrhagic shock secondary to multiple stab wounds including perforation of the heart. Accused-appellant pleaded not guilty and offered alibi testimony that he was at a billiards hall from about seven until ten in the evening, corroborated by his sister and a third party, and pointed to Mark’s alleged failure to identify him in police line-ups; the Regional Trial Court of Quezon City, Branch 76 convicted him of robbery with homicide in its November 16, 2005 Decision and ordered reclusion perpetua plus indemnities and damages, the Court of Appeals affirmed that conviction on September 28, 2007, and the case reached the Supreme Court on appeal where the conviction was affirmed with modification to the monetary awards by imposing legal interest at six percent per annum from finality.
Issues:
Was the prosecution able to prove beyond reasonable doubt that accused-appellant committed the special complex crime of
robbery with homicide? Was the deaf-mute eyewitness,
Mark Almodovar, competent and credible to identify accused-appellant and testify to the events he witnessed? Does an alleged failure to identify the accused in a police line-up fatally undermine an eyewitness’s in-court identification? Were the penalty and the awards of civil indemnity, moral damages and actual damages properly determined and interest properly imposed?
Ruling:
Ratio:
Doctrine: