People v. Pulusan
REITERATIONFacts
The Antecedents: On January 20, 1986, four men boarded a passenger jeepney along the Bulacan-Pampanga highway. They announced a hold-up, divested passengers of their valuables, killed four passengers, and repeatedly raped the sole female passenger. Three victims survived to testify: the driver, a fifty-year-old man, and the raped girl. Procedural History: The accused, Eduardo Pulusan y Aniceta and Rolando Rodriguez y Macalino, were charged with highway robbery with multiple homicide and multiple rape. Rolando Tayag and John Doe alias Ramon/Efren were also charged but remained at large. The Regional Trial Court of Bulacan found Pulusan and Rodriguez guilty of robbery with homicide and sentenced them to reclusion perpetua, ordering them to indemnify the heirs of the deceased and the rape victim. The accused appealed, primarily questioning their identification and the credibility of prosecution witnesses. The Petition: Appellants Pulusan and Rodriguez argued that the trial court erred in giving credence to their identification, in giving evidentiary weight to allegedly unreliable testimonies, in failing to give exculpatory weight to their alibis, and in convicting them without proof beyond reasonable doubt.
Issue(s)
Whether the trial court erred in giving credence to the identification of the accused by prosecution witnesses. Whether the alibis presented by the accused were sufficient to overcome the positive identification by the prosecution witnesses. Whether the accused conspired in the commission of the crime. Whether the accused are guilty of highway robbery with homicide and rape.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused Eduardo Pulusan and Rolando Rodriguez guilty of robbery with homicide. The Court modified the monetary awards, increasing the civil indemnity for the heirs of the slain victims and the moral damages for the rape victim. The penalty imposed remains reclusion perpetua.
Ratio Decidendi
On the identification of the accused: The Court held that the trial court's findings on the credibility of witnesses are entitled to the highest degree of respect. Despite the fear experienced by the witnesses, they were able to obtain occasional glances of the perpetrators, which, under the circumstances including the lighting conditions inside the jeepney and from following vehicles, were sufficient for identification. The Court noted that witnesses do not need perfect recall, and minor inconsistencies in their testimonies are indicative of veracity rather than fabrication. The identification by multiple eyewitnesses further strengthened the prosecution's case. On the alibis of the accused: The Court found the alibis of Pulusan and Rodriguez to be unmeritorious. The alibis did not establish that it was physically impossible for them to have been at the crime scene during its commission. More importantly, their alibis collapsed in the face of positive identification by the prosecution witnesses, which is given greater weight than an alibi. On conspiracy: The Court found that the prosecution sufficiently proved conspiracy among the four men. Conspiracy may be deduced from the mode and manner of the commission of the offense, pointing to a joint purpose and design. The simultaneous boarding of the jeepney, the coordinated announcement of the hold-up, the divesting of valuables, the commission of rape, and the infliction of fatal injuries on the passengers all demonstrated unity of purpose and design. Thus, the act of one conspirator is imputable to all. On the crime charged: The Court affirmed the trial court's finding that the accused were guilty of robbery with homicide under Article 294(1) of the Revised Penal Code, not highway robbery as defined by PD 532, as there was no proof of organization for indiscriminate robbery. The Court clarified that the number of homicides is immaterial in robbery with homicide, and rape committed on the occasion is an aggravating circumstance. Given that the death penalty had not yet been reimposed by law at the time of the crime, the imposable penalty was reclusion perpetua, which is a single indivisible penalty.
Main Doctrine
The crime of robbery with homicide is a special complex crime punishable by reclusion perpetua to death. The number of homicides committed on the occasion of a robbery is immaterial and does not increase the penalty. Rape committed on the occasion of robbery with homicide is considered an aggravating circumstance, not a principal offense, unless it was the original intention. The penalty for robbery with homicide, even with aggravating circumstances, is reclusion perpetua if the death penalty has not yet been reimposed by law at the time of the commission of the crime.