People v. Enriquez
REITERATIONFacts
The Antecedents: On December 12, 1957, Catalino Enriquez and Benigno Alcantara allegedly entered the house and store of Siaba, inflicted severe injuries upon Siaba and his housemaids Edita Balingcasag and Flaviana Licanda, resulting in their deaths, and stole P500 in cash and goods worth P166.10. Procedural History: A complaint for robbery with triple homicide was filed against appellants Enriquez and Alcantara. They waived preliminary investigation, and the provincial fiscal filed an information. The Court of First Instance of Zamboanga del Sur convicted them and sentenced each to life imprisonment, ordering them to jointly pay restitution and indemnify the heirs of the deceased. The Petition: Defendants-appellants appealed the decision, raising issues regarding the identity of the malefactors and the sufficiency of evidence to establish robbery.
Issue(s)
Whether the evidence presented sufficiently established the identity of the malefactors. Whether the crime of robbery was committed. Whether the penalty imposed by the lower court was correct.
Ruling
The Supreme Court affirmed the decision of the lower court with modifications regarding the amounts of restitution and indemnity. The penalty of life imprisonment for robbery with triple homicide was upheld.
Ratio Decidendi
On the identity of the malefactors: The Court found the testimony of prosecution witness Ramon Mambi, alias Ambi Banin, to be credible. Mambi, a household member of Siaba and a first cousin of the appellants, provided a plain, simple, and straightforward account of the events. His testimony was corroborated by Nia Laya, who confirmed that Siaba identified Alcantara as the thief who wounded him. The Court found the defense witnesses' testimonies to be unworthy of credence, noting inconsistencies and contradictions, particularly with Albain Isnain's testimony which was disproven by other witnesses and the physical evidence. The Court also highlighted that Mambi had no motive to falsely incriminate his own cousins. On whether robbery was committed: The Court found sufficient evidence to establish that robbery was committed. Siaba's widow testified that a trunk was forced open and that cash and goods were missing. The appellants' own testimonies and that of their witness Albain Isnain, despite their attempts to shift blame, indicated that the purpose of the culprits was to steal. The Court reasoned that the maids would not have been killed if the primary purpose was not robbery. The total value of stolen items was established at P666.10. On the penalty imposed: The Court reiterated the established jurisprudence that the crime of robbery with homicide is a single and indivisible offense, even if multiple homicides are perpetrated in the course thereof. Therefore, only one penalty, that prescribed for robbery with homicide, should be imposed, as correctly done by the lower court. The Court cited several previous rulings to support this principle. The Court did, however, modify the restitution and indemnity amounts.
Main Doctrine
The crime of robbery with homicide is a single and indivisible offense, and only one penalty should be imposed for it, even if multiple homicides are committed in the course thereof. The restitution for the stolen goods and the indemnity for the deaths of the victims are separate civil liabilities that must be awarded.