People v. Teodoro
REITERATIONFacts
The Antecedents: On February 3, 1992, Wilfredo G. Teodoro and Vic Naguit allegedly went to the house of Eden M. Cabarubias. Margie Ganaban, a housemaid, let them in. After Cabarubias finished her bath, she spoke with Teodoro. Ganaban, after taking her bath, was met by Teodoro at the door of the room. Teodoro allegedly covered her mouth, pushed her against the wall, and stabbed her three times on the upper right chest. Ganaban then heard Cabarubias pleading for her life, followed by sounds of ransacking. Ganaban fainted and later crawled out of the house to seek help. Police officers responded, and Cabarubias was found on the garage floor and brought to the hospital, where she later died. Teodoro was identified by Ganaban and Ruel Cabarubias, the father of the deceased. Teodoro surrendered to the police on February 7, 1992. Procedural History: Two informations were filed against appellant Teodoro: one for robbery with homicide (Criminal Case No. 91327) and another for frustrated homicide (Criminal Case No. 91328). The trial court, the Regional Trial Court of Pasig, Metro Manila, Branch 156, found appellant guilty beyond reasonable doubt of robbery with homicide and sentenced him to suffer the penalty of reclusion perpetua. He was also ordered to indemnify the heirs of Eden M. Cabarubias and pay Margie M. Ganaban. The Petition: Appellant Wilfredo G. Teodoro appealed the Joint Decision of the trial court, assigning as error the finding of guilt for robbery with homicide despite evidence to the contrary and the testimony of an eyewitness in his favor.
Issue(s)
Whether the appellant is guilty of robbery with homicide. Whether the appellant is guilty of frustrated homicide. Whether moral damages were properly awarded.
Ruling
The Supreme Court modified the decision of the trial court. It found the appellant guilty of homicide and frustrated homicide, not robbery with homicide. The award for moral damages and reimbursement of stolen cash was deleted. The appellant was sentenced to an indeterminate penalty for homicide and frustrated homicide.
Ratio Decidendi
On the charge of robbery with homicide: The Court disagreed with the trial court's conclusion that the appellant was guilty of robbery with homicide. It reiterated the settled rule that for a conviction of robbery with homicide, robbery must be proven as conclusively as the killing itself; otherwise, the offense is only homicide or murder. In this case, Margie Ganaban only heard the ransacking of the room and did not actually see the appellant or his companion take any money. Furthermore, there was no sufficient proof that a sum of money was left in the deceased's room or that the appellant took any money. The testimony of Ruel Cabarubias regarding the money was based on inferences and inconclusive recollections. Therefore, the Court found no sufficient evidence to justify the finding that the killing was attended by asportation of money. On the charge of frustrated homicide: The Court found no dispute that the appellant is liable for frustrated homicide. The victim, Margie Ganaban, would have died had it not been for the timely medical attention she received. The appellant himself conceded that, if at all, he should be convicted only of this offense. The Court noted that Margie Ganaban's testimony, despite her serious injuries, was credible as she did not immediately lose consciousness and was able to perceive and identify her assailant. Her clear, simple, and straightforward account established that appellant Teodoro stabbed her and subsequently stabbed Eden Cabarubias. On the award of moral damages: The Court deleted the award of P20,000.00 as moral damages to the heirs of Eden Cabarubias. It held that moral damages cannot be awarded in the absence of proof of physical suffering, mental anguish, fright, serious anxiety, besmirched reputation, wounded feelings, moral shock, social humiliation, and similar injury, as required by Article 2217 of the Civil Code. The Court found no factual basis for the award in the records of the case.
Main Doctrine
A conviction for the special complex crime of robo con homicidio can be sustained only when robbery is proven as conclusively as the killing itself; otherwise, the offense is only homicide. Furthermore, the findings of a trial court on the credibility of witnesses and the weight it gave their testimonies are, as a rule, accorded respect, even finality, by appellate courts.