People vs. Feliciano

G.R. No. 102078 (May 15, 1996)

Rolando Feliciano was convicted of Robbery with Homicide; Supreme Court upheld the ruling.

Facts:

On May 30, 1988, Rolando Feliciano, his brother Rogelio Feliciano, and an unidentified accomplice entered the home of 68-year-old Rosario FariAas in Quezon City, claiming to wait for her son-in-law, Ben Junio. Present in the house were Rosario, her brother Marciano FariAas, and a 13-year-old helper, Nelia Basilio. After being invited to lunch, Rolando Feliciano brandished a knife at Rosario, while Rogelio pointed a gun at Marciano, and the third man threatened Nelia with a knife. Without provocation, Rolando stabbed Rosario three times, fatally wounding her. The assailants then forced Marciano to retrieve money, taking a total of P1,000 and $200 from him, as well as an undetermined amount of U.S. dollars from Rosario's room. When Marciano refused to provide more money, Rolando stabbed him multiple times, but he survived after medical treatment.

Rolando Feliciano was arrested on December 5, 1990, after a police chase. He was charged with Robbery with Homicide. The prosecution's case relied heavily on the eyewitness testimonies of Nelia Basilio and Marciano FariAas, while the defense presented an alibi, claiming Rolando was elsewhere at the time of the crime.

Legal Issues:

  1. Whether the prosecution proved beyond reasonable doubt the guilt of Rolando Feliciano for the crime of Robbery with Homicide.
  2. Whether the defense of alibi presented by Rolando Feliciano was credible and sufficient to exonerate him from the charges.

Arguments:

Prosecution:

  • The prosecution argued that the testimonies of Nelia Basilio and Marciano FariAas clearly identified Rolando Feliciano as one of the assailants. Nelia testified that she recognized Rolando as the person who stabbed Rosario and that she was familiar with him prior to the incident.
  • The prosecution emphasized the lack of motive for Nelia to falsely accuse Rolando and pointed out that her identification of him was consistent and credible.

Defense:

  • Rolando Feliciano contended that the trial court failed to establish his guilt and that the eyewitness testimony was unreliable. He highlighted that Nelia's first affidavit did not mention his name, which he argued was critical to discrediting her testimony.
  • The defense presented an alibi, claiming that Rolando was at home during the time of the crime, supported by testimonies from his wife and a neighbor. They asserted that the inconsistencies in the testimonies of the prosecution witnesses created reasonable doubt regarding Rolando's involvement.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding Rolando Feliciano guilty beyond reasonable doubt of Robbery with Homicide. The court held that the identification of Rolando by Nelia Basilio was credible and corroborated by the circumstances of the crime. The court noted that the absence of his name in Nelia's first affidavit did not negate her later identification during the trial, as it is not uncommon for witnesses to fail to recall names immediately after a traumatic event.

The court also found the defense of alibi unconvincing, as the testimonies presented were inconsistent and did not provide a solid basis for Rolando's whereabouts at the time of the crime. The court emphasized that positive identification of the accused by a credible witness outweighs an alibi.

The court recognized that the crime of Robbery with Homicide is a single indivisible offense under Article 294 of the Revised Penal Code, which carries a penalty of reclusion perpetua to death. Given the constitutional prohibition against the death penalty, the court imposed the penalty of reclusion perpetua.

Significant Legal Principles Established:

  • The identification of an accused by a witness during trial can be sufficient for conviction, even if the accused's name is not mentioned in earlier statements.
  • The credibility of eyewitness testimony is paramount, especially when the witness has prior knowledge of the accused.
  • The presence of aggravating circumstances, such as the crime being committed in the dwelling of the victim, can influence the penalty but does not alter the nature of the crime itself.