People v. Fabula
REITERATIONFacts
The Antecedents: On August 24, 1992, at approximately 8:00 in the evening, an elderly couple, Mariano Cueto and Petra Cueto, were robbed and killed near their residence in Barangay Gamao, Naujan, Oriental Mindoro. The accused, Edilberto Fabula alias "Eden", Kano Fabula, Ricky Cusi, and John Doe, were charged with Robbery with Double Homicide. The Information alleged that the accused, with intent to gain and conspiring together, unlawfully and feloniously took P15,000.00 from the spouses by means of force and intimidation. On the occasion of the robbery, to enable them to take the money, the accused attacked and stabbed the spouses, causing their instantaneous death. Procedural History: Only Edilberto "Eden" Fabula was arraigned and tried, as the other accused were at large. The prosecution presented eyewitness Bernardo Lingasa, who testified that he saw accused Edilberto "Eden" Fabula grab Petra's bag and stab her, and that Eden's companion stabbed Mariano Cueto when he rushed to his wife's aid. Lingasa also testified that Eden stated, "Tayo na Kuya Kano, patay na yang mga yan." Danilo Cueto, son of the victims, corroborated the taking of Petra's bag by testifying that his mother was seen counting P15,000.00 the day before the incident and that the bag was missing after the incident. The accused interposed the defense of denial and alibi, claiming he was at his parents' house in Sta. Cruz, Calapan, Oriental Mindoro on the night of the incident. The Regional Trial Court (RTC) convicted Edilberto Fabula of Robbery with Double Homicide and sentenced him to two terms of reclusion perpetua, ordering him to pay indemnity. The Petition: The accused-appellant appealed, asserting that the prosecution twisted the facts and suppressed evidence favorable to him, and assailing the credibility of prosecution witnesses due to alleged inconsistencies. The Supreme Court noted that the appellant's brief violated the Rules of Court by failing to include a subject index, statement of the case, statement of facts, assignment of errors, and a prayer for relief.
Issue(s)
Whether the accused-appellant's appeal brief complied with the Rules of Court. Whether the prosecution sufficiently proved the guilt of the accused-appellant for the crime of Robbery with Double Homicide beyond reasonable doubt. Whether the accused-appellant's defense of alibi is credible and sufficient to acquit him. Whether the accused-appellant was correctly sentenced to two terms of reclusion perpetua for the crime of Robbery with Double Homicide, and the propriety of the monetary awards.
Ruling
The Supreme Court affirmed the conviction of the accused-appellant but modified the sentence. The Court found that the appellant's brief was fatally defective for non-compliance with the Rules of Court. On the merits, the Court held that the eyewitness testimony positively identifying the accused-appellant was credible and sufficient to overcome his uncorroborated alibi. However, the Court ruled that the crime of Robbery with Double Homicide does not exist as a special complex crime under Article 294, paragraph 1 of the Revised Penal Code. The Court clarified that the penalty for robbery with homicide is a single reclusion perpetua, regardless of the number of victims killed on the occasion of the robbery. The Court also ordered the accused-appellant to pay the sum of P15,000.00, representing the money stolen.
Ratio Decidendi
On the compliance with the Rules of Court: The Court found that the accused-appellant's brief was fatally defective as it failed to comply with the mandatory requirements of Section 16 of Rule 46 of the Rules of Court. Specifically, it lacked a subject index, a statement of the case, a statement of facts, an assignment of errors, and a prayer for relief. These omissions were deemed "fatal" and highlighted the "bankruptcy" of the appeal, indicating a lack of serious legal effort. On the guilt of the accused-appellant: The Court found that the prosecution had proven the guilt of the accused-appellant beyond reasonable doubt. This was primarily based on the positive identification by eyewitness Bernardo Lingasa, whose testimony was found to be clear and unequivocal during both direct and cross-examination. The Court saw no cogent reason to disturb the trial court's conclusion regarding Lingasa's credibility, especially since there was no showing of any evil motive on the part of the witness. On the defense of alibi: The Court rejected the accused-appellant's defense of alibi. The Court emphasized that an alibi must not only prove the accused was not at the scene of the crime but also that it was absolutely impossible for him to be there. The accused-appellant's claim of sleeping at his parents' house in Sta. Cruz, Calapan, Oriental Mindoro, was uncorroborated and did not establish the impossibility of his presence at Barangay Gamao, Naujan, Oriental Mindoro, on the night of the incident. His uncorroborated alibi crumbled in the face of positive identification by an eyewitness. On the penalty for Robbery with Double Homicide and the monetary awards: The Court clarified that the crime of Robbery with Double Homicide, as charged, does not exist as a distinct special complex crime in Philippine penal law. Article 294, paragraph 1 of the Revised Penal Code penalizes robbery with homicide with a single penalty of reclusion perpetua. This penalty encompasses all homicides committed by reason or on the occasion of the robbery, irrespective of the number of victims. Therefore, the trial court erred in imposing two terms of reclusion perpetua for the deaths of Mariano and Petra Cueto. The Court affirmed the trial court's order for indemnity for the deaths of the victims. Additionally, the Court corrected the trial court's omission by ordering the accused-appellant to pay the sum of P15,000.00, representing the amount of money forcibly stolen from the victims during the robbery, as this was an integral part of the offense.
Main Doctrine
The crime of robbery with homicide is a special complex crime punishable under Article 294, paragraph 1 of the Revised Penal Code, and it does not allow for separate penalties for each homicide committed when perpetrated by reason or on the occasion of the robbery, regardless of the number of victims. The penalty for this crime is a single indivisible penalty of reclusion perpetua.