In People vs. Yatco, the Supreme Court affirmed the conviction of Angelito Yatco for robbery with homicide, underscoring the principle that a weak alibi cannot outweigh the positive identification of an accused by credible witnesses. The Court emphasized the importance of eyewitness testimony, especially when the witnesses have no apparent motive to falsely accuse the defendant. This decision clarifies that for an alibi to hold weight, the accused must demonstrate the physical impossibility of being at the crime scene, not just that they were elsewhere. This case serves as a reminder of the high standard of proof required to overcome strong eyewitness accounts in criminal proceedings.

Eyewitness Account vs. Alibi: Who Pulled the Trigger?

The case revolves around the tragic death of Enrico Rivera, a driver/helper for San Miguel Corporation, who was shot and robbed of company funds while making deliveries in Laguna. Two witnesses, Normelito Robes and Mario Cena, identified Angelito Yatco as the assailant. Robes, an independent observer, witnessed the crime from across the street, while Cena, Rivera’s fellow truck helper, saw Yatco fleeing with the stolen money immediately after the shooting. Yatco, in his defense, claimed he was elsewhere at the time, fetching his daughter from school. This alibi, however, failed to convince the trial court, which found Yatco guilty and sentenced him to death, a decision that was later modified by the Supreme Court on appeal.

At the heart of Yatco’s appeal was the credibility of the eyewitnesses. He argued that Robes’s and Cena’s testimonies were inconsistent and unreliable. Yatco highlighted discrepancies between Robes’s initial sworn statement and his testimony regarding distances, as well as the delayed reporting of the incident to the police. Similarly, he pointed out that Cena’s initial affidavit lacked a description of the assailant. The Supreme Court, however, dismissed these arguments, citing the well-established principle that minor inconsistencies do not necessarily discredit a witness and that affidavits are often incomplete. More importantly, the Court emphasized that the two eyewitnesses identified Angelito Yatco at trial: “The witness pointing to a man who answered by the name [of] Angelito Yatco.“

The Court affirmed the trial court’s reliance on the positive identification of Yatco by the eyewitnesses. It reiterated that findings on witness credibility are given utmost respect, absent any clear indication that the trial court overlooked or misapplied relevant facts. Positive identification, where a witness unequivocally identifies the accused as the perpetrator, carries significant weight in the judicial process. It is a direct assertion of the accused’s presence and involvement at the scene, directly challenging any claims of innocence or mistaken identity. This is amplified when such identifications are made consistently and without signs of bias. In Yatco’s case, both witnesses directly identified him in court as being directly involved.

Contrasting with the positive identification, Yatco’s defense rested on alibi and denial. An alibi requires not only proof that the accused was somewhere else when the crime occurred but also a demonstration that it was physically impossible for them to be at the crime scene. Yatco’s alibi failed on both counts. He claimed he was at his home in Tagapo, Santa Rosa, Laguna, the same town where the crime occurred, making it entirely possible for him to be at the scene of the crime. Therefore, alibi alone isn’t enough to be excused for a crime.

The Court found no reason to disregard the testimonies of Robes and Cena, especially since no ill motive was attributed to them. In the absence of any demonstrable bias or ulterior motive, witnesses are presumed to testify truthfully. As such, the legal standard leans towards crediting their accounts. If they have no motivation, this truth is magnified. To be persuasive, Yatco’s denial had to demonstrate more. The court must not give the other witness’ statements less weight, as in this situation. As the prosecution had proven beyond a reasonable doubt Yatco’s commission of the offense, he was guilty of said crime.

Under Article 294(1) of the Revised Penal Code, robbery with homicide carries a penalty of reclusion perpetua to death. However, the court found no aggravating or mitigating circumstances to justify the imposition of the death penalty; accordingly, it reduced the penalty to reclusion perpetua. Additionally, the Court addressed the issue of damages, modifying the amounts awarded to the heirs of Rivera to include civil indemnity of P50,000, moral damages of P50,000, and actual damages of P39,775, corresponding to the funeral expenses supported by receipts. Moreover, the loss of earning capacity was adjusted based on Rivera’s age, income, and living expenses.

Art. 294(1). Robbery with violence against or intimidation of persons – Penalties. – Any person guilty of robbery with the use of violence against or intimidation of any person shall suffer:

1. The penalty of reclusion perpetua to death, when by reason or on occasion of the robbery, the crime of homicide shall have been committed . . .

FAQs

What was the key issue in this case?	The primary issue was whether the accused’s alibi and denial could outweigh the positive identification made by two eyewitnesses who placed him at the scene of the robbery with homicide. The Court prioritized those eyewitness identifications above Yatco’s defense, sealing the verdict.
What is required for an alibi to be considered a valid defense?	For an alibi to hold weight, the accused must not only prove that they were somewhere else when the crime was committed, but also demonstrate that it was physically impossible for them to be at the crime scene at that time. This rigorous burden makes alibi inherently difficult to show to a legal certainty.
Why did the Supreme Court reduce the penalty from death to reclusion perpetua?	The trial court’s original decision to impose the death penalty was overturned on the grounds that neither aggravating nor mitigating circumstances were proven during the trial. As such, reclusion perpetua (life imprisonment) was the appropriate lesser penalty.
What is civil indemnity, and why was it awarded in this case?	Civil indemnity is a sum automatically granted to the heirs of a victim in a criminal case, without the need for proof. The Court awarded it here to acknowledge the loss suffered by the family of Enrico Rivera due to his unlawful death.
What is the legal definition of Robbery with Homicide?	Robbery with homicide, under Article 294(1) of the Revised Penal Code, occurs when there is a taking of personal property with intent to gain, through violence or intimidation, and on the occasion of the robbery, a homicide is committed. Proving all aspects must meet a threshold, to properly indict.
How is the loss of earning capacity calculated in damages?	The formula used calculates the net earning capacity by factoring in the victim’s life expectancy, gross annual income, and necessary living expenses. Life expectancy accounts for two-thirds, multiplied by subtracting 80 from the age of the deceased.
Why were the inconsistencies in the witnesses’ affidavits not enough to discredit their testimony?	The Supreme Court stated that inconsistencies in witness affidavits are expected due to the affidavits being incomplete accounts recorded outside court proceedings. Further supporting the view that any misstatements in these records are the product of circumstance, not any falsification.
What happens when the judge who pens a decision wasn’t there for the original trial?	According to the court, a judge can make rulings as long as stenographic records of the original trial, were properly assessed to do so. As well as there aren’t compelling arguments regarding the integrity or correctness of any decisions rendered.

The People vs. Yatco case demonstrates the critical weight that positive eyewitness identification carries in Philippine jurisprudence, especially when contrasted with the weaker defense of alibi. It underscores that positive and credible identification, combined with the absence of ill motive, constitutes substantial evidence that can lead to a conviction. The decision reinforces the legal standard requiring the accused to prove the physical impossibility of their presence at the crime scene, not merely that they were somewhere else. This highlights the constant need for thorough defense preparations and also highlights that simply asserting claims isn’t persuasive.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PEOPLE OF THE PHILIPPINES, VS. ANGELITO YATCO, G.R. No. 138388, March 19, 2002