People v. Cobre
REITERATIONFacts
The Antecedents: On October 4, 1988, accused-appellant Oscar Cobre, along with Agustin Ortiz, Papias Jaba, and Mario Carreon, had an altercation with their employer, Renato Biteranta, regarding their wages. Biteranta refused to pay them for the entire month as it was not yet over. Following this refusal, Jaba kicked Biteranta, then armed himself with a .38 caliber pistol. Carreon and Cobre armed themselves with shotguns. Biteranta attempted to flee but was pursued. Jaba took Biteranta's wallet and shot but missed. Accused-appellant Cobre then shot Biteranta with his shotgun, causing his death. During the incident, Renato Guzman, Biteranta's godson, and his family were tied up on orders of Cobre. The accused fled with stolen items including a telescope, flashlight, cutter, and battery, after disabling Biteranta's jeep and releasing his horses. Procedural History: The Regional Trial Court of Tanay, Rizal, convicted Oscar Cobre of the Special Complex Crime of Robbery with Homicide and sentenced him to suffer the penalty of reclusion perpetua. The court also ordered him to pay P50,000.00 to the heirs of the deceased. The Petition: Accused-appellant Oscar Cobre appealed the decision, assigning errors concerning the trial court's disregard of defense evidence and the failure to prove his guilt beyond reasonable doubt.
Issue(s)
Whether the prosecution sufficiently proved that accused-appellant Oscar Cobre was the one who shot the victim, Renato Biteranta. Whether the prosecution proved beyond reasonable doubt that accused-appellant Oscar Cobre committed the crime of Robbery with Homicide. Whether the trial court erred in disregarding the evidence for the defense.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding accused-appellant Oscar Cobre guilty of the Special Complex Crime of Robbery with Homicide and sentencing him to suffer the penalty of reclusion perpetua. The Court ordered the accused-appellant to pay P50,000.00 to the heirs of the deceased.
Ratio Decidendi
On the issue of whether accused-appellant Oscar Cobre was the one who shot the victim: The Supreme Court rejected the accused-appellant's argument that it was Papias Jaba who shot the victim. State witness Agustin Ortiz categorically testified that he saw accused-appellant Oscar Cobre shoot Renato Biteranta with a shotgun. Ortiz's vantage point near the door, approximately two to three meters away, allowed him to witness the shooting. Furthermore, the medico-legal officer, Dr. Desiderio Moraleda, testified that the victim sustained seven shotgun wounds, and based on the points of entry, inferred that only one shotgun was used. This contradicted the defense's claim that Jaba, who had a .38 caliber pistol, was the shooter. The Court found the testimony of Ortiz to be credible and unwavering. On the issue of whether the prosecution proved beyond reasonable doubt that accused-appellant Oscar Cobre committed the crime of Robbery with Homicide: The Supreme Court found that the prosecution successfully established the elements of Robbery with Homicide. The evidence showed that the accused, including the appellant, conspired to commit the crime. They entered the victim's farm, used force and intimidation, stole items belonging to the victim, and on the occasion of the robbery, shot and killed Renato Biteranta. The Court reiterated the well-settled rule that when homicide is committed as a consequence or on the occasion of robbery, all principals in the robbery are guilty of robbery with homicide, even if they did not directly participate in the killing, unless they endeavored to prevent it. The accused-appellant's participation in the robbery and the subsequent homicide, through conspiracy, was sufficiently proven. On the issue of whether the trial court erred in disregarding the evidence for the defense: The Supreme Court found no error in the trial court's assessment of the evidence. The accused-appellant's defense consisted mainly of denial and an attempt to shift blame to Papias Jaba. The Court characterized denial as an inherently weak defense that cannot prevail over positive and credible testimony. The accused-appellant's story was uncorroborated and contradicted by the state witness. The discrepancy in the testimonies of prosecution witnesses Guzman and Ortiz, as alleged by the defense, was not significant enough to warrant acquittal, especially given Ortiz's clear and consistent account of the shooting and the physical evidence supporting it. The Court found no reason to doubt the trial court's appreciation of the evidence presented.
Main Doctrine
When homicide is committed as a consequence or on the occasion of robbery, all those who took part as principals in the robbery will also be held guilty as principals of the special complex crime of robbery with homicide, although they did not actually take part in the homicide, unless they endeavored to prevent the unlawful killing.