Title
People vs. Mendoza y Cruz
Case
G.R. No. L-34290
Decision Date
Mar 28, 1980
Roberto Mendoza, a gang member, was convicted of robbery with homicide after stabbing jeepney passengers in 1970. Witnesses identified him; his alibi was rejected. Death penalty commuted to life imprisonment.

Case Summary (G.R. No. L-34290)

Crime Details and Victim Information

During the incident, Francisco Garido was driving a jeepney with multiple passengers when three men boarded the vehicle. The attackers demanded that Garido stop the jeepney before proceeding to rob the occupants of their belongings and inflicting injuries with knives. The violence resulted in the death of one passenger, Oscar Tagudin, from stab wounds. Another passenger, Claro Dabajo, sustained serious injuries but survived. Alicia Victoria also suffered from stab wounds during the attack. The sequence of events escalated with the attackers fleeing the scene after a gunshot was fired.

Arrest and Defense

Fifty-three days after the robbery, Mendoza was identified as one of the suspects and arrested. At trial, he asserted an alibi, contending he was visiting his grandmother at the time of the crime. However, his defense was undermined by the failure of his witness, Belinda Diaz, to corroborate his claims about his whereabouts. Furthermore, Alicia Victoria, a key witness, positively identified Mendoza as one of the robbers during the preliminary identification process and in a police lineup. This identification was critical to the prosecution's case.

Court Proceedings and Verdict

The trial court's proceedings examined the testimony and evidence presented by both sides. The court found Mendoza's alibi unconvincing and gave substantial weight to the eyewitness accounts, particularly that of the victims. The court ruled that the identification by Alicia Victoria, supported by the jeepney driver's testimony, was credible and consistent. The trial court ultimately convicted Mendoza of robbery with homicide, emphasizing the gravity of his actions in the commission of the crime, aggravated by craft and abuse of superiority.

Sentencing and Appeals

Initially sentenced to death, the case was automatically elevated for review due to the imposition of the death penalty. The defense counsel, appointed to represent Mendoza in the automatic review, contended that the evidence did not conclusively establish his guilt beyond reasonable doubt, citing failures in eyewitness identification. However, the reviewing court upheld the trial court's judgment, affirming the conviction while commutating the death sentence to reclusion perpetua due to a lack of requisite votes for the death penalty.

Civil Liabilities

In addition to the criminal conviction, the court addressed civil liabilities, ordering Mendoz

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