People v. Calegan
REITERATIONFacts
The Antecedents: Eliseo Calegan y Mataverde, along with co-accused Florentino Frasdilla and Wilfredo Magat, were charged with robbery with homicide. The Information alleged that on or about June 4, 1988, in Kalookan City, the three, conspiring together, forcibly took a .38 caliber revolver valued at P6,000.00 from Allan Ibardolaza. During the commission of the robbery, they shot and killed Ibardolaza by firing a shot into the back of his head, causing his death. Procedural History: Only Eliseo Calegan y Mataverde was tried as his co-accused were not apprehended. The Regional Trial Court of Kalookan City, on December 21, 1989, convicted Calegan of robbery with homicide and sentenced him to reclusion perpetua. He was ordered to return the stolen revolver or reimburse its value and to indemnify the heirs of Allan Ibardolaza. The case against Frasdilla and Magat was archived. Calegan appealed the decision. The Petition: In his appeal, accused-appellant Eliseo Calegan y Mataverde challenged the credibility of the sole eyewitness, Edmundo Legislador. The arguments raised were: (a) discrepancies between Legislador's sworn statement and his court testimony regarding the timing of his observation of the abduction; (b) a contradiction concerning whether Legislador reported the incident to P/Cpl. Alberto David at the police headquarters, which David denied; and (c) the assertion that Legislador was a biased witness due to his relationship with the victim and the security agency. The Supreme Court, however, affirmed the conviction, finding the discrepancies minor and the explanations sufficient, and deferred to the trial court's assessment of the witness's credibility.
Issue(s)
Whether the credibility of the sole prosecution witness, Edmundo Legislador, was sufficiently established despite alleged discrepancies and bias. Whether the accused-appellant Eliseo Calegan is guilty beyond reasonable doubt of the crime of robbery with homicide.
Ruling
The Supreme Court affirmed the decision of the trial court, finding accused-appellant Eliseo Calegan guilty beyond reasonable doubt of the special complex crime of robbery with homicide. The sentence of reclusion perpetua was affirmed, and the indemnity to the heirs of the victim was increased.
Ratio Decidendi
On the credibility of the sole prosecution witness, Edmundo Legislador: The Court held that discrepancies between an affidavit and court testimony do not necessarily discredit a witness, especially when the affidavit is taken ex-parte and may be incomplete or inaccurate. The alleged inconsistencies regarding whether Legislador was on the bus or waiting for it when he witnessed the incident were deemed trivial, as the significant circumstance of witnessing the crime remained common to both accounts. The Court found Legislador's explanation for the discrepancy in his sworn statement sufficient, attributing it to the police officer's haste and his own failure to read the statement before signing. The alleged inconsistency about reporting the incident to P/Cpl. David was also considered minor, as even truthful witnesses can make innocent lapses. The Court found no bias that would render Legislador's testimony inadmissible or devoid of probative value, noting that his relationship with the victim and the agency owner did not inherently disqualify him or show ill motivation. The Court deferred to the trial court's assessment of Legislador's credibility, having observed his demeanor during testimony. On the guilt of the accused-appellant Eliseo Calegan for robbery with homicide: The Court found that conspiracy to commit robbery was conclusively shown by the coordinated acts of the three accused, as narrated by Legislador. The crime of homicide was committed on the occasion of the robbery. The Court reiterated the doctrine that where conspiracy is established, the act of one is the act of all. Therefore, even if Calegan did not personally shoot the victim, he is equally guilty of the special complex crime of robbery with homicide because he took part as a principal in the robbery, which was the occasion for the homicide. The defense of alibi and denial presented by Calegan were correctly disregarded by the trial court for lack of clear and convincing supporting evidence, and because the corroborating witness, Marina Vanzuela, was found to have doubtful credibility due to her delayed statements and failure to report the incident to the police earlier.
Main Doctrine
Where conspiracy is shown to exist, the act of one is the act of all. 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.