Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Roberto Soriano y Bruan, also known as "Ruben," and Salvador Mejia, also known as "Adong," as the accused-appellants. The events transpired near midnight on August 11, 1980, in Amangcosiling Norte, Bayambang, Pangasinan. Leonora Corpuz, a school teacher, was alarmed by her dog’s incessant barking and went to investigate with her son, Marcelino Corpuz, and her brother-in-law, Natalio Solomon. Upon checking, they noticed pebbles being thrown at Leonora's chico tree and observed that the dog had gone towards the camarin, where the pebble-throwers presumably were. Shortly after, the dog returned and collapsed, appearing to have been poisoned with "vetsin." While they were trying to revive the dog, two armed men, later identified as Roberto Soriano and Salvador Mejia, confronted them, ordering them not to move. Soriano then shot Marcelino Corpuz, who fell to the grou...

Facts:

Incident Details

• Date and Time: Near midnight of August 11, 1980.
• Location: Amangcosiling Norte, Bayambang, Pangasinan.
• Victim: Marcelino Corpuz, son of Leonora Corpuz.
• Accused: Roberto Soriano y Bruan @ "Ruben," Salvador Mejia @ "Adong," and Restituto Ferrer.
• Initial Event: Leonora Corpuz, a school teacher, was alarmed by her dog's continuous barking. She, along with her son Marcelino and brother-in-law Natalio Solomon, investigated the disturbance.
• Discovery: They found pebbles being thrown at a chico tree, and the dog appeared to have been poisoned with "vetsin."
• Attack: Two men, identified as Roberto Soriano and Salvador Mejia, suddenly appeared, brandishing firearms. Soriano shot Marcelino Corpuz, who died on arrival at the hospital. The dog was also taken by the assailants.

Investigation and Arrest

• Investigation: Conducted by Sgt. Eustino Maure and other peace officers the following day. They recovered an empty carbine shell and dried fish laced with "vetsin."
• Identification: Leonora Corpuz and Natalio Solomon identified the suspects but requested that the complaint be filed only after their arrest due to fear of retaliation.
• Arrest: The suspects were arrested on various dates, with Restituto Ferrer being the last on June 16, 1981.

Legal Proceedings

• Charges: An information was filed on January 4, 1982, charging the accused with robbery with homicide under Article 294(1) of the Revised Penal Code.
• Arraignment: All accused pleaded not guilty. Roberto Soriano jumped bail and was tried in absentia.
• Judgment: On April 17, 1986, the Trial Court found Soriano and Mejia guilty beyond reasonable doubt and sentenced them to reclusion perpetua. Restituto Ferrer was acquitted due to insufficient evidence.
• Death of Soriano: Soriano died on December 17, 1985, before the judgment was promulgated, extinguishing his criminal liability.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Identification of the Accused:

   • The identification of Soriano and Mejia by Leonora Corpuz and Natalio Solomon was credible. The witnesses had sufficient opportunity to recognize the accused due to the well-lit environment and their prior familiarity with them.
   • The delay in executing affidavits was justified by the witnesses' fear of retaliation from the accused, who were known criminals in the community.

2. Alibi Defense:

   • The defense of alibi cannot prevail over positive identification by credible witnesses. The accused failed to demonstrate the physical impossibility of their presence at the crime scene.

3. Civil Liability:

   • The civil indemnity was increased to P50,000.00 in line with current jurisprudence, reflecting the gravity of the crime and the loss suffered by the victim's heirs.

Conclusion:

The Supreme Court affirmed the Trial Court's judgment with modifications, deleting the conviction of Roberto Soriano due to his death and increasing the civil indemnity to P50,000.00. The conviction of Salvador Mejia was upheld based on credible identification and the failure of his alibi defense.