Facts:

• The case involves People of the Philippines vs. Teodoro Esmale y Badion and Juan Tresvalles, Jr. y Trope.
• The accused were charged with Robbery with Homicide under an Amended Information dated January 10, 1986.
• The incident took place on September 27, 1985, in Marikina, Metro Manila.
• The prosecution claimed the accused, along with two others, conspired to rob a passenger jeepney driven by Melencio Abenojar.
• During the robbery, they forcibly took an Alba wristwatch valued at P600.00 and P10.00 in cash from passenger Leonardo Diwa.
• Diwa was stabbed when he attempted to resist, resulting in his death.
• Eyewitnesses Reynaldo Balbastro and Antonio Sosa testified about the robbery and the actions of the assailants.
• After the robbery, the victims were ordered to disembark in a secluded area.
• An autopsy confirmed that Diwa died from stab wounds.
• Teodoro Esmale was arrested on October 16, 1985, and confessed, naming Juan Tresvalles, Jr. as a co-conspirator.
• Tresvalles was arrested based on Esmale's confession.
• Esmale's defense was denial, claiming torture during confession; Tresvalles presented an alibi.
• The trial court found both guilty beyond reasonable doubt and sentenced them to Reclusion Perpetua with financial restitution.

Issue:

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Ruling:

• The Supreme Court reversed the conviction of Juan Tresvalles, Jr.
• The Court found the identification of Tresvalles as a perpetrator doubtful and insufficient for conviction.
• The testimonies of t...(Unlock)

Ratio:

• The Supreme Court emphasized the necessity of credible identification in criminal cases.
• Gerardo Francisco, a key witness, did not testify in court, making his out-of-court identification hearsay and inadmissible.
• Reynaldo Balbastro's testimony was inconsistent and failed to convincingly identify Tresva...continue reading