Facts:

The case involves Angelito Yatco, the accused-appellant, who was found guilty of robbery with homicide by the Regional Trial Court, Branch 24, 4th Judicial Region, Biñan, Laguna, in a decision dated November 23, 1998. The incident occurred on January 6, 1994, in Sta. Rosa, Laguna, where Enrico Rivera y Yalong, a driver and helper for San Miguel Corporation, was shot and killed during a robbery. At approximately 3:20 PM, while Enrico was delivering beer with two helpers, he was attacked by Yatco, who attempted to steal cash amounting to P7,320.35. Witnesses, including Normelito Robes and Mario Cena, testified that they saw Yatco grappling with Enrico before he shot him and fled the scene with the money. Enrico was declared dead on arrival at the hospital, with the autopsy revealing that he died from a gunshot wound to vital organs. Yatco, upon arrest, claimed he was at home during the incident and alleged police torture during his detention. The trial court found him guilty an...

Facts:

1. Incident Overview: On January 6, 1994, in Sta. Rosa, Laguna, Angelito Yatco was accused of robbing and killing Enrico Rivera, a driver/helper for San Miguel Corporation. The robbery involved the theft of P7,320.35, and Rivera was shot dead during the incident.
2. Victim’s Role: Enrico Rivera was performing dual roles as a driver and substitute salesman for San Miguel Corporation at the time of the incident. He was accompanied by helpers Mario Cena and Eduardo Bicatan.
3. Eyewitness Testimony: Normelito Robes, a warehouse helper, witnessed the incident from a distance of about 4 meters. He saw Yatco grappling with Rivera, shooting him, and then fleeing with the stolen money.
4. Autopsy Report: Dr. Rolando Poblete conducted an autopsy on Rivera’s body, confirming that the cause of death was a gunshot wound to vital organs, leading to cardio-respiratory arrest.
5. Defense’s Alibi: Yatco claimed he was at home during the incident, fetching his daughter from school and preparing dinner. He also alleged that he was tortured by police officers during his arrest.
6. Police Investigation: SPO2 Victor Torres and SPO4 Rodolfo Macatangay denied allegations of torture and confirmed that Yatco was identified in a police line-up by witnesses Robes and Cena.

Issue:

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Ruling:

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Ratio:

1. Credibility of Witnesses: The Court emphasized that the trial court’s findings on witness credibility are entitled to great respect and will not be disturbed unless there is clear evidence of oversight or misapplication of facts.
2. Alibi Defense: The defense of alibi is inherently weak and cannot prevail over the positive identification of the accused by credible witnesses. The accused must also prove that it was physically impossible for him to be at the crime scene.
3. Penalty Application: Under Article 294(1) of the Revised Penal Code, robbery with homicide carries a penalty of reclusion perpetua to death. In the absence of aggravating circumstances, the lesser penalty of reclusion perpetua should be imposed.
4. Damages: Civil indemnity is automatically granted to the heirs of the victim without the need for proof. Actual damages must be supported by receipts, and loss of earning capacity should be computed based on established formulas.