People v. Domingo
REITERATIONFacts
The Antecedents: On or about June 1, 1984, in Cabanatuan City, Bonifacio Domingo, Ernesto Calderon, Charlito Pascual, and Danilo Perez were charged with Robbery with Homicide. The Information alleged that the accused, armed with guns and a knife, conspired to rob Juan P. Garcia's store, taking cash and jewelry valued at P100,700.00. During the robbery, Juan P. Garcia suffered a stroke due to extreme fear when the robbers pointed guns at him, which directly caused his death. Procedural History: Only Ernesto Calderon, Charlito Pascual, and Danilo Perez were arrested and arraigned. They pleaded not guilty. After trial, the Regional Trial Court of Nueva Ecija, Branch IV, found them guilty beyond reasonable doubt of Robbery with Homicide and sentenced each to suffer reclusion perpetua. They were ordered to indemnify the heirs of Juan P. Garcia in the sum of P100,700.00, with each accused liable for one-fourth (1/4) thereof, and the remaining one-fourth (1/4) to be shouldered by the accused Bonifacio Domingo, who was still at large. Subsidiary imprisonment in case of insolvency was also imposed. The Petition: The accused-appellants appealed to the Supreme Court, raising the issue of the credibility of the prosecution witnesses, Flora Farfaran and Renato Garcia, and whether their testimonies were sufficient to sustain a judgment of conviction.
Issue(s)
Whether the testimonies of Flora Farfaran and Renato Garcia were credible enough to sustain a judgment of conviction. Whether the accused-appellants are guilty of the crime of Robbery with Homicide. Whether the penalty imposed by the trial court is correct. Whether the indemnity awarded to the heirs of the victim is proper, and the extent of liability among the accused. Whether subsidiary imprisonment in case of insolvency is applicable.
Ruling
The judgment of the Regional Trial Court finding the accused Ernesto Calderon, Charlito Pascual, and Danilo Perez guilty of Robbery with Homicide is affirmed, with modifications. The accused-appellants are sentenced to pay, jointly and severally, the heirs of the victim the amount of P130,700.00, without subsidiary imprisonment in case of insolvency.
Ratio Decidendi
On the credibility of witnesses: The Supreme Court reiterated the well-settled rule that appellate courts will not generally disturb the findings of the trial court on the credibility of witnesses unless certain facts of substance and value have been plainly overlooked, which, if considered, might affect the result of the case. The appellants failed to demonstrate that their case falls under this exception. Minor discrepancies in the testimonies of witnesses are natural and expected, and they even enhance credibility as they indicate honest and unrehearsed answers. The Court found no serious contradictions in the testimonies of Flora Farfaran and Renato Garcia that would warrant overturning the trial court's findings. The alleged inconsistencies regarding the identification of the assailants and their weapons were explained by the Court as minor details or misinterpretations, not substantial contradictions that would cast doubt on the guilt of the accused. On the crime of Robbery with Homicide: The Court affirmed the trial court's finding that the appellants were guilty of Robbery with Homicide. Citing former Chief Justice Ramon C. Aquino, the Court stated that it is immaterial that death supervened by mere accident as long as the homicide was produced by reason or on the occasion of the robbery. The law considers only the result obtained, without reference to the circumstances, causes, modes, or persons intervening in the commission of the crime. In this case, the victim died as a direct consequence of the extreme fear induced by the robbers during the commission of the robbery. On the penalty: The penalty of reclusion perpetua imposed by the trial court was affirmed. The Court noted that while the mitigating circumstance of lack of intention to commit homicide was considered, it was offset by the aggravating circumstance of dwelling. The Court also clarified that the penalty of reclusion perpetua is correct for robbery with homicide, as defined and penalized under Article 294, paragraph 1, of the Revised Penal Code. On the indemnity: The trial court erred in ordering the appellants to pay only P100,700.00, which represented only the value of the stolen property. The Court modified the judgment to include P30,000.00 as indemnity for the death of Juan P. Garcia, making the total indemnity P130,700.00. The Court also corrected the trial court's error in ordering each appellant to pay only one-fourth (1/4) of the indemnity. The Court held that the accused-appellants, being principals, are solidarily liable for the entire amount of the indemnity under Article 110 of the Revised Penal Code. The reservation for Bonifacio Domingo was removed as he had not yet been tried. On subsidiary imprisonment: The Court ruled that the trial court erred in ordering subsidiary imprisonment in case of insolvency. With the amendment of Article 39 of the Revised Penal Code by Republic Act No. 5465, subsidiary penalty applies only to non-payment of fines. Furthermore, before and after Republic Act No. 5465, there is no subsidiary penalty when the principal penalty meted out is higher than prision correccional. Since the penalty imposed was reclusion perpetua, subsidiary imprisonment was not applicable.
Main Doctrine
The crime of robbery with homicide is committed when, in the course of a robbery, a homicide results, regardless of whether the death was intended or accidental. The penalty for robbery with homicide is reclusion perpetua. All principals in the commission of the crime are solidarily liable for the civil indemnity awarded to the heirs of the victim.