Case Summary (G.R. No. 138388)

Conviction and Sentencing Overview

• The accused-appellant, Angelito Yatco, was convicted of Robbery with Homicide and sentenced to death.
• The conviction was based on eyewitness testimonies identifying Yatco as the assailant who shot the victim, Enrico Rivera, and stole P7,320.35.
• Yatco contested the credibility of the eyewitnesses and the reliability of the trial court's decision, arguing that the judge who rendered the decision did not personally hear the case.

Credibility of Witnesses

• The trial court's findings on witness credibility are given the highest respect and are not disturbed on appeal unless there is a clear error.
• The eyewitnesses provided consistent and straightforward testimonies, which the Supreme Court found trustworthy due to favorable visibility conditions and lack of bias.

Affidavit Inconsistencies

• Discrepancies between witness affidavits and court testimonies do not inherently discredit the witnesses, as affidavits are often incomplete and inaccurate.
• The inconsistencies noted were deemed inconsequential and did not undermine the core fact that Yatco was the shooter.

Defense of Alibi

• The defense of alibi is considered weak and cannot outweigh positive identification by witnesses.
• For an alibi to be credible, the accused must demonstrate that it was physically impossible for him to be at the crime scene, which Yatco failed to do.

Validity of Judicial Decision

• The fact that Judge Pablo Francisco, who penned the decision, was not the original trial judge does not invalidate the decision.
• The complete case records were available to Judge Francisco, allowing for a thorough review and evaluation before rendering the decision.

Elements of Robbery with Homicide

• The elements required to establish Robbery with Homicide were present: taking property through violence, intent to gain, and the commission of homicide during the robbery.
• The prosecution successfully established Yatco's responsibility for the killing of Enrico, confirming that the crime was indeed robbery with homicide.

Review of Trial Court's Decision

• The trial court's imposition of the death penalty was found to be erroneous as the law prescribes reclusion perpetua to death for robbery with homicide.
• The absence of aggravating or mitigating circumstances necessitated the application of the lesser penalty, which is reclusion perpetua.

Damages Awarded

• The trial court failed to award civil indemnity to the victim's heirs...continue reading