People v. Lacatan
REITERATIONFacts
The Antecedents: On November 23, 1990, at around 8:00 to 8:30 in the evening, in barangay G. Antonio, municipality of Gloria, province of Oriental Mindoro, Rommel Lacatan, Ruby Villamarin, and Dominador Salazar, conspiring and confederating, armed with bladed instruments, allegedly committed robbery with homicide. They took cash money amounting to P100,000.00, assorted jewelries valued at P50,000.00, and assorted foodstuff valued at P20,000.00, belonging to Alfredo Salazar and his wife, Anicia Lamonte. On the occasion of the robbery, they allegedly attacked, stabbed, and killed Alfredo Salazar with evident premeditation, treachery, abuse of superior strength, nocturnity, and cruelty. Procedural History: The Information was filed on March 14, 1992. The accused pleaded not guilty. The prosecution presented eyewitness Eduardo Ruallo, the victim's children Elmer Salazar and Edna Salazar, widow Anicia Salazar, Pat. Delfin Yumang, and Dr. Edgardo N. Hernandez. The defense presented Rodolfo Umbao, Ruel Suppleo, and the appellants themselves. The Regional Trial Court, Branch 42, Pinamalayan, Oriental Mindoro, found the accused guilty beyond reasonable doubt of Robbery with Homicide under Article 294, paragraph 1 of the Revised Penal Code, with aggravating circumstances of evident premeditation, abuse of superior strength, nocturnity, and cruelty, and sentenced each to suffer the penalty of reclusion perpetua. They were also ordered to indemnify the heirs of Alfredo Salazar. The Petition: The accused appealed the decision of the RTC, arguing that the prosecution failed to establish the elements of robbery with homicide, that the trial court erred in giving full faith and credit to the uncorroborated testimony of Eduardo Ruallo, and that they were not guilty beyond reasonable doubt.
Issue(s)
Whether the prosecution sufficiently established the elements of the crime of Robbery with Homicide. Whether the testimony of the sole eyewitness, Eduardo Ruallo, is credible and sufficient for conviction. Whether the defense of alibi presented by the appellants is tenable.
Ruling
The Court affirmed the decision of the Regional Trial Court, finding the accused-appellants guilty beyond reasonable doubt of the crime of Robbery with Homicide. The penalty of reclusion perpetua was upheld, along with the civil indemnity and damages awarded.
Ratio Decidendi
On the sufficiency of elements for Robbery with Homicide: The Court found that the prosecution successfully proved the commission of robbery and that on the occasion thereof, homicide was committed. The Information clearly alleged that the accused, by means of violence and intimidation, took cash, jewelries, and goods belonging to the victim, and that on the occasion of this robbery, they killed Alfredo Salazar. The eyewitness testimony corroborated the taking of the items, and the autopsy report confirmed the death of the victim due to stab wounds. The Court reiterated that the essential elements of robbery with homicide are: (1) the taking of personal property is committed with violence or intimidation against persons; (2) the property taken belongs to another; (3) the taking is done with intent to gain; and (4) on the occasion of the robbery or by reason thereof, the victim is killed. On the credibility of the sole eyewitness, Eduardo Ruallo: The Court gave full faith and credit to the testimony of Eduardo Ruallo. Despite the defense's attempts to discredit him by pointing out alleged inconsistencies regarding the location where the victim was dragged, the absence of bloodstains in the sala, and the number of weapons used, the Court found these points to be minor and inconsequential. The Court held that the exact part of the house where the victim was dragged is trivial, and the absence of bloodstains could be explained by absorption by clothing or by the bloodstains being wiped clean. The medico-legal officer's opinion on the use of two weapons did not necessarily contradict the eyewitness's account, as the witness might not have observed all details. Furthermore, the Court found the delay in reporting the crime to be excusable due to fear of reprisal, a well-established valid excuse. The Court emphasized that the testimony of a single credible and positive witness is sufficient for conviction, and there was no proof of improper motive for Ruallo to implicate the appellants. On the tenability of the defense of alibi: The Court rejected the defense of alibi presented by the appellants. The Court reiterated the well-settled rule that alibi, being easy to concoct, cannot prevail over the positive identification by a credible prosecution witness. Moreover, the appellants failed to prove that it was physically impossible for them to have been at the scene of the crime at the approximate time of its commission. The distances between their residences and the victim's house were relatively short, making their presence at the crime scene entirely possible. The Court stressed that for alibi to prosper, the requirements of time and place must be strictly met, and it is not enough to show they were elsewhere; they must demonstrate physical impossibility of being at the crime scene.
Main Doctrine
The crime of robbery with homicide is committed when a homicide is perpetrated by reason or on the occasion of the robbery. The Court affirmed the conviction of the accused for robbery with homicide, finding that the prosecution sufficiently established the elements of the crime and the guilt of the accused beyond reasonable doubt, despite the defense of alibi.