People v. Robedillo
REITERATIONFacts
1. The Antecedents: The case involves the murder of Martiano Cinco. The prosecution alleged that on May 30, 1988, in Tolosa, Leyte, Eduardo "Eddie" Robedillo, Artemio "Artem" Yepes, Artemio "Artem" Novio, and Anacleto "Yontong" Novio conspired to kill Martiano Cinco. They allegedly attacked Cinco with bladed weapons, inflicting fatal wounds to his head, chest, and back, taking advantage of treachery and superior strength. 2. Procedural History: The accused were charged with murder in the Regional Trial Court (RTC) of Palo, Leyte. Trial proceeded against Eduardo Robedillo, Artemio Yepes, and Anacleto Novio, as Artemio Novio remained at large. The RTC found Robedillo, Yepes, and Anacleto Novio guilty of murder and sentenced them to reclusion perpetua, with joint and several indemnity to the victim's heirs. Artemio Yepes died during the pendency of the appeal. Anacleto Novio jumped bail. This appeal is primarily before the Supreme Court concerning Eduardo Robedillo. 3. The Petition: Accused-appellant Eduardo Robedillo, through his counsel, filed an appeal to the Supreme Court, raising a single issue: whether the RTC gravely erred in convicting him of murder instead of the lesser offense of homicide. The appellant invoked the ruling in People v. Narciso, arguing that the qualifying circumstance of superior strength could not be considered if blows were delivered alternately. The Supreme Court, however, found this argument without merit, distinguishing the facts from Narciso and emphasizing the evidence of conspiracy and the collective force employed by the appellants in committing the crime.
Issue(s)
Whether the qualifying circumstance of superior strength was properly appreciated by the trial court, and whether conspiracy was sufficiently established. Whether the appeal of Anacleto Novio, who jumped bail, should be dismissed. Whether the appeal of Artemio Yepes, who died during the pendency of the appeal, should be dismissed. Whether the civil indemnity should be modified.
Ruling
The Supreme Court affirmed the decision of the trial court with modifications. The appeals of Artemio Yepes and Anacleto Novio were dismissed. The civil indemnity was increased to P50,000.00. The trial court was directed to issue warrants for the arrest of Anacleto Novio and the forfeiture of his bail bond, and to commit Eduardo Robedillo to the Bureau of Corrections.
Ratio Decidendi
On the conviction for murder, the appreciation of superior strength, and conspiracy: The Court rejected the argument that the use of superior strength could not be considered because the accused delivered blows alternately, distinguishing this case from People v. Narciso. There was clear evidence of conspiracy among the accused to kill the victim. They acted in concert, surrounded the victim to block his escape, and effectively prevented him from defending himself, demonstrating the collective force they employed. This conspiracy to use their superior strength was evident from the eyewitness testimonies and the number and nature of the wounds inflicted. Conspiracy does not require a previous plan; it is sufficient if, at the time of the aggression, all the accused manifested by their acts a common intent or desire to attack. On the dismissal of Anacleto Novio's appeal and his denial: The appeal of Anacleto Novio was dismissed because he jumped bail, despite warrants for his arrest. His escape is considered an indication of guilt. His denial, claiming lack of motive, could not prevail against the positive identification by the two eyewitnesses. His claim of being falsely accused due to a past altercation was also unsubstantiated. On the dismissal of Artemio Yepes' appeal: The appeal of Artemio Yepes was dismissed due to his death during the pendency of the appeal, as per Rule 125, §1 in relation to Rule 124, §8 of the Rules of Court. On the modification of civil indemnity: The Court found it just and equitable to increase the civil indemnity awarded by the trial court from P30,000.00 to P50,000.00, consistent with prevailing jurisprudence at the time of the decision.
Main Doctrine
Conspiracy to use superior strength is shown not only by testimonies but also by the number and nature of stab wounds suffered by the victim. Escape after conviction is an indication of guilt.