G.R. No. L-34290 - People vs. Mendoza y Cruz

On April 27, 1970, at approximately 10:45 p.m., Francisco Garido was driving his jeepney from Quiapo, Manila to Pasay City with several passengers aboard.
The jeepney was lighted and was making its regular route when the incident occurred.

At the intersection of Taft Avenue and Herran (Pedro Gil) Streets, three men boarded the jeepney.
Shortly after boarding, one of the men ordered the driver to stop the vehicle, prompting Garido to comply.

Once the jeepney halted at the next block or near the Philippine Women’s University on Taft Avenue, the three ruffians commenced their assault.
They divested the passengers of their valuables, specifically wristwatches, and stabbed both the driver and the passengers with knives.
Amid the mayhem, a gunshot was heard, and the malefactors fled the scene toward Remedios Street in the direction of M. Adriatico Street.

Victims included the driver, Francisco Garido, and passengers Alicia Victoria, Claro Dabajo, and Oscar G. Tagudin.
Oscar Tagudin, aged 20, sustained a fatal stab wound in the abdomen that lacerated his left kidney and abdominal aorta, dying upon arrival at the hospital; he also had an incised wound on the left wrist.
Claro Dabajo, aged 27, suffered a stab wound in the abdomen that affected his intestines and kidney. Although his valuable (a Titus wristwatch valued at one hundred pesos) was taken, he survived due to timely medical attention.
Alicia Victoria, aged 19, sustained an abdominal stab wound and was hospitalized for six days; her Seiko wristwatch (valued at one hundred eighty pesos) was taken but later recovered from the snatcher.
Francisco Garido incurred only a slight stab wound in the arm while also suffering the loss of earnings amounting to twenty-five pesos stored in his box.

Fifty-three days after the holdup, Roberto Mendoza, aged 24, a construction helper and a member of the Sigue-Sigue Sputnik (SSS) gang from Makati, Rizal, was charged in the Circuit Criminal Court of Manila as one of the three malefactors.
Mendoza faced charges for robbery with homicide and multiple serious physical injuries.
At trial, Mendoza presented an alibi, testifying that he was on vacation at his grandmother’s house in the Robes Subdivision, San Jose, Bulacan.
He further explained that after being arrested for vagrancy in Paco, Manila, he was taken by Constabulary CIS agents to Alicia Victoria’s residence and later to Camp Crame, Quezon City, where he was allegedly released due to lack of evidence.

Mendoza relied on the alibi testimony and offered Belinda Diaz, his alleged common-law wife, as a corroborating witness.
Belinda Diaz’s testimony became inconsistent—she initially corroborated the alibi but then testified that Mendoza’s wife was a different woman named Helen before retracting to admit she was, in fact, his wife.
The trial court rejected his alibi and gave credence to the positive identifications made by Alicia Victoria and the jeepney driver.

Mendoza was convicted of robbery with homicide, aggravated by craft and abuse of superiority.
He was sentenced to death and ordered to pay civil indemnity including: an indemnity of thirty-two thousand pesos to the heirs of Oscar Tagudin, the return or payment for Alicia Victoria’s watch, and compensation for the twenty-five pesos stolen from Garido.

Without appealing the trial court’s decision, Mendoza’s case was elevated to the Supreme Court for automatic review of the death penalty.
The defense, through counsel de oficio, argued that the evidence of guilt was not proven beyond a reasonable doubt, emphasizing the failures and inconsistencies in the witness identifications specifically by Claro Dabajo, the driver, and Alicia Victoria.

Was the identification of Roberto Mendoza by Alicia Victoria and the jeepney driver reliable given the circumstances of both initial and subsequent identifications?
How does the delay in the identification process (identification a week after the event and again during the trial) affect the reliability of the testimony?

Can Mendoza’s alibi of being in Bulacan, corroborated by Belinda Diaz, overcome the weight of positive eyewitness identifications?
What is the impact of the inconsistent testimony rendered by Belinda Diaz regarding Mendoza’s marital status on the credibility of the alibi?

Considering the conflicting identifications and the challenges to the alibi, does the evidence collectively meet the standard of proof required for conviction in a case of robbery with homicide?
How do the inconsistencies in evidence affect the determination of guilt in such a grave offense?

Was the imposition of the death penalty justified based on the evidence presented, especially when set against the procedural issues raised?
How does the Absorption Doctrine (whereby homicide absorbs the lesser offenses of physical injuries) factor into the severity of the sentence, and what are the implications of converting the death penalty to reclusion perpetua?