People v. Saulo
REITERATIONFacts
The Antecedents: On January 25, 1987, in Quezon City, the accused, David Saulo y Santos, allegedly robbed Oscar Ilustre y Ilagan of a gold necklace and P500.00 in cash by means of violence and intimidation. During the commission of the robbery, the accused allegedly stabbed the victim with a kitchen knife, inflicting serious and mortal wounds which caused his death. Procedural History: The Regional Trial Court of Quezon City, Branch 104, found the accused guilty beyond reasonable doubt of Robbery with Homicide and sentenced him to suffer the penalty of reclusion perpetua, to indemnify the heirs of the deceased in the amount of P200,000.00 for funeral and other expenses, and to pay costs. The Petition: The accused appealed the decision, raising the sole assignment of error that the trial court erred in finding him guilty beyond reasonable doubt as the evidence presented was insufficient to overcome his constitutional right to be presumed innocent.
Issue(s)
Whether the evidence presented is sufficient to prove the guilt of the accused beyond reasonable doubt for the crime of robbery with homicide. Whether the aggravating circumstance of dwelling should be appreciated.
Ruling
The Supreme Court modified the decision of the trial court. The accused-appellant David Saulo y Santos was found guilty beyond reasonable doubt of the special complex crime of robbery with homicide with the aggravating circumstance of dwelling. He was sentenced to suffer the penalty of reclusion perpetua and ordered to pay to the heirs of the deceased the death indemnity of P50,000.00. The award of P200,000.00 for funeral and other expenses was deleted.
Ratio Decidendi
On the sufficiency of evidence and the guilt of the accused: The Court affirmed the trial court's finding of guilt beyond reasonable doubt. The testimonies of the prosecution eyewitnesses, Benjamin Berto and Jesus Donato, who were house helpers of the victim, were found credible. They testified that they saw the accused stabbing the victim. They also testified to finding the victim's necklace and cash in the accused's pockets after subduing him. The Court found the defense's claims, such as the possibility of the house helpers framing the accused or the police planting evidence, to be unsubstantiated and self-serving. The Court reiterated the rule that the findings of the trial court on the credibility of witnesses are given great weight and respect. The presence of the stolen items in the accused's possession, coupled with the eyewitness accounts of the stabbing, established the elements of robbery with homicide. On the aggravating circumstance of dwelling: The Court appreciated the aggravating circumstance of dwelling because the crime was committed in the house of the victim. The Court cited that the crime was committed at the house of the victim, thus dwelling is an aggravating circumstance. This circumstance, when present in robbery with homicide, calls for the imposition of the death penalty under Article 63(4) of the Revised Penal Code. However, due to the constitutional prohibition against the imposition of the death penalty, the penalty was reduced to reclusion perpetua, consistent with existing jurisprudence.
Main Doctrine
The crime of robbery with homicide is a special complex crime. The aggravating circumstance of dwelling is appreciated when the offense is committed in the house of the victim. The penalty for robbery with homicide, with the aggravating circumstance of dwelling, is reclusion perpetua to death, but due to the prohibition against the death penalty, reclusion perpetua is imposed. The death indemnity is P50,000.00.