People v. Moreno, Jr.
REITERATIONFacts
The Antecedents: On October 12, 1981, Oscar Guevarra, Sr. reported his son, Oscar Guevarra, Jr., missing. The victim was last seen driving a Toyota Corolla. Five days later, the victim's body was found at Funeraria Popular, bearing 13 stab wounds. The victim's car was recovered in Tondo, Manila, stripped of its parts. Four individuals, Alfredo Moreno, Jr., Antonio Gonzales, Noli Rivera, and Froilan Jacinto, were charged with robbery with homicide. Procedural History: The Information charged the accused with conspiring and confederating together, armed and acting in band, to commit robbery with homicide. They allegedly used a firearm to force the victim into his car, took the vehicle, and then killed him by hitting him with the gun butt and stabbing him multiple times. Froilan Jacinto was discharged as a state witness and acquitted. Noli Rivera remains at large. Accused Alfredo Moreno, Jr. and Antonio Gonzales were found guilty of robbery with homicide, with the aggravating circumstance of abuse of superior strength, and were sentenced to reclusion perpetua. They were also ordered to pay various indemnities. The Petition: The accused-appellants averred that the trial court erred in giving credence to the testimony of state witness Froilan Jacinto and in finding that conspiracy existed among them.
Issue(s)
Whether the trial court erred in giving credence to the testimony of the state witness. Whether conspiracy was sufficiently established among the accused. Whether the accused-appellants are guilty of the special complex crime of robbery with homicide.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the accused-appellants guilty beyond reasonable doubt of the special complex crime of robbery with homicide, with slight modifications in the amount of indemnity. The Court increased the civil indemnity from P30,000.00 to P50,000.00.
Ratio Decidendi
On the credibility of the state witness: The Court found the testimony of Froilan Jacinto to be credible and consistent with his statements during the investigation. The testimony was corroborated by the statements of the other accused, who provided an almost identical narration of the events, including the hold-up, the trip to Meycauayan, the stabbing of the victim, the dumping of the body, the subsequent accident with a truck, and the cannibalization of the car in Tondo. The trial court, as the best judge of witness credibility, gave it credence, and its findings are entitled to great weight and respect on appeal. On the existence of conspiracy: The Court held that conspiracy need not be established by direct evidence but may be proven through a series of acts done in pursuance of a common unlawful purpose. In this case, the concerted acts of the accused in holding up the victim, taking his car, killing him, and stripping the car of its parts strongly indicated conspiracy to commit robbery. Once conspiracy to commit robbery is established, all participants are liable for the consequences, including homicide, unless they attempted to prevent the killing. On the guilt of the accused-appellants for robbery with homicide: The Court reiterated that robbery with homicide is a special complex crime where the real motive is robbery, and homicide is committed by reason or on the occasion thereof. It is inconsequential whether the homicide preceded the robbery, as long as there is a direct link between the two felonies, driven by the prospect of monetary gain. In this case, the accused Moreno commenced the hold-up, Gonzales and Rivera assisted with weapons, all participated in the killing by stabbing, and they took the victim's car and stripped it. Therefore, all participants in the robbery are principals in the complex crime of robbery with homicide.
Main Doctrine
Conspiracy to commit robbery having been established by the concerted acts of the accused, and homicide occurred as a consequence thereof, all those who participated in the robbery are principals in the complex crime of robbery with homicide, although they did not actually take part in the homicide, unless it appears that they attempted to prevent the killing.