Case Digest (G.R. No. 176159)
Facts:
People of the Philippines v. Lee Rodrigo, G.R. No. 176159, September 11, 2008, the Supreme Court Second Division, Brion, J., writing for the Court.The criminal case arose from a holdup and killing at a restaurant in Area H, San Rafael, Bulacan on October 27, 2000 in which the victim, Paquito Buna, was shot and died; his wife Rosita Cabrera‑Buna (Rosita) was the principal complaining witness. Rosita later filed a Sinumpaang Salaysay (dated November 24, 2000) in which she stated that three armed men — identified to her by a third party as “Bunso,” “Lyn‑lyn,” and Lee Rodrigo — robbed the restaurant of P500.00 and that one of the men shot her husband. Rosita testified at trial that she saw Rodrigo among the three robbers and identified him in court.
Rodrigo was arrested on May 29, 2001 and, together with two still‑at‑large co‑accused, was charged with robbery with homicide. At trial the People presented Rosita as its sole eyewitness and stipulated the medico‑legal officer’s findings; the defense presented only Rodrigo who pleaded not guilty and advanced denial and alibi, claiming he was at home some one kilometer away (a 10‑minute ride) at the time of the crime. Rosita admitted on re‑cross that she initially identified Rodrigo by means of a single photograph shown to her at the police station and that she later saw and pointed him out at the police station and in court.
The Regional Trial Court (RTC), Branch 11, Malolos City, convicted Rodrigo on June 27, 2005 of robbery with homicide (Article 294(1), RPC), sentenced him to reclusion perpetua and awarded damages, finding Rosita’s in‑court identification credible and rejecting Rodrigo’s alibi/denial. The Court of Appeals (CA), in CA‑G.R. CR.‑H.C. No. 01531, affirmed with modification on September 18, 2006, reducing the civil indemnity award to P50,000.00. Rodrigo appealed to this Court, challenging (1) that the prosecution failed to prove guilt beyond reasonable doubt and (2) that the lower courts relied on the weakness of his defense rather than the strength of the prosecution’s case. The medico‑legal testimony was stipulated and the prosecution rested after presenting documentary evidence (Sinumpaang Salaysay, funeral expenses, death certificate).
Issues:
- Was the identity of the accused proven beyond reasonable doubt given the prosecution’s reliance on a prior out‑of‑court photographic identification followed by a single eyewitness (Rosita)?
- Were the elements of robbery with homicide sufficiently proven so as to overcome the presumption of innocence and render Rodrigo’s defenses of denial and alibi immaterial?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)