People v. Manlapaz
REITERATIONFacts
The Antecedents: On May 18, 1992, the victim, Israel Lacson, was driving a passenger jeepney with Ruel Lopez Dayrit as his companion. They picked up two male passengers. Upon reaching Henson Street, one passenger ordered the driver to stop. Instead of paying the fare, the two passengers drew guns. One held Dayrit while the other grabbed the money box. When Lacson refused to give the money box, he was shot in the head, causing his death. The accused-appellant, Romano Manlapaz, was charged with Robbery with Homicide along with Renato Pena. Procedural History: The Regional Trial Court (RTC) of Angeles City, Branch 59, found Romano Manlapaz guilty beyond reasonable doubt of Robbery with Homicide and sentenced him to reclusion perpetua. The RTC also ordered him to pay damages. The Petition: Accused-appellant Romano Manlapaz appealed the RTC decision, arguing that his guilt was not proven beyond reasonable doubt.
Issue(s)
Whether the guilt of the accused-appellant was proven beyond reasonable doubt. Whether the prosecution sufficiently established the existence of conspiracy. Whether the identification of the accused-appellant by the eyewitness was positive and credible. Whether the imposed penalty and damages are proper.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellant guilty beyond reasonable doubt of Robbery with Homicide and sentencing him to reclusion perpetua. The Court also affirmed the awards for actual damages and death indemnity, with a modification on the hospitalization expenses.
Ratio Decidendi
On the issue of whether the guilt of the accused-appellant was proven beyond reasonable doubt: The Court found that the eyewitness, Ruel Lopez Dayrit, positively identified Romano Manlapaz as one of the perpetrators. Despite the accused-appellant's bare denial and claim of not being clearly identified, Dayrit's testimony was found to be credible and unwavering. The Court noted that Dayrit's shock after the incident did not render him incapable of identifying the assailant, as it is natural for victims to observe their assailants. The defense failed to establish any ill motive on the part of the witness for falsely implicating the accused-appellant. Therefore, the positive identification by a credible witness was sufficient to establish guilt beyond reasonable doubt. On the issue of whether the prosecution sufficiently established the existence of conspiracy: The Court held that while direct proof of an agreement to commit the crime may be wanting, conspiracy can be deduced from the simultaneous boarding of the jeepney by the two accused, their concerted actions of drawing guns, attempting to rob the victim, and fleeing the scene together. The Court reiterated the principle that in conspiracy, the act of one is the act of all, making it unnecessary to determine who precisely fired the fatal shot. The lower court's finding on conspiracy, which was affirmed by the Supreme Court, was based on the deduction from their synchronized actions. On the issue of whether the identification of the accused-appellant by the eyewitness was positive and credible: The Court found Dayrit's identification of Manlapaz to be positive and categorical. Although Dayrit did not know Manlapaz prior to the incident, he clearly saw the events unfold as he was seated beside the driver. He was able to pinpoint Manlapaz from a police lineup and identify him in court. The Court found no reason to doubt Dayrit's credibility, noting that his testimony was corroborated by the autopsy findings regarding the location of the gunshot wound. The defense's attempt to impeach Dayrit's testimony based on his state of shock was deemed insufficient. On the issue of whether the imposed penalty and damages are proper: The Court affirmed the penalty of reclusion perpetua for the crime of Robbery with Homicide, as provided under Article 294 of the Revised Penal Code, in the absence of modifying circumstances. The Court sustained the awards for actual damages for burial and funeral expenses amounting to P11,500.00, as these were duly supported by receipts. The hospitalization expenses were reduced to P3,466.00, as this was the amount substantiated by receipts. The award of P50,000.00 as death indemnity was also affirmed, in accordance with prevailing jurisprudence.
Main Doctrine
Conspiracy can be deduced from the mode and manner by which the offense was perpetrated, and when established, the act of one is the act of all. A bare denial, unsubstantiated by clear and convincing evidence, cannot prevail over the positive testimony of a credible witness.