People v. Matic
REITERATIONFacts
The Antecedents: On October 12, 1994, Rolando Villamin y Mutas was allegedly robbed of ₱50.00 and stabbed, resulting in his death. The Information charged Ramil Matic y Bactad and Norberto Sotelo y Soriano, along with two John Does, with Robbery with Homicide. Procedural History: Appellant Ramil Matic pleaded not guilty. During trial, he manifested a desire to plead guilty, but the court proceeded to receive further evidence. An amended information was filed regarding Norberto Sotelo, who remained at large. The Regional Trial Court (RTC), Branch 160, Pasig City, convicted appellant Ramil Matic y Bactad of Robbery with Homicide and sentenced him to reclusion perpetua. The Petition: Appellant assails his conviction, arguing that the testimony of prosecution witness Jimmy Escala was tainted with doubts and contradictions, and that the trial court erred in finding him guilty of Robbery with Homicide.
Issue(s)
Whether the testimony of prosecution witness Jimmy Escala is credible despite alleged inconsistencies with his sworn statement. Whether the elements of the special complex crime of Robbery with Homicide were sufficiently proven. Whether the defense of alibi, coupled with denial, can prevail over positive identification.
Ruling
The Supreme Court affirmed the conviction of Ramil Matic y Bactad for Robbery with Homicide, sentencing him to reclusion perpetua. The award of exemplary damages was deleted. The Court affirmed the awards of civil indemnity, actual damages, and moral damages.
Ratio Decidendi
On the credibility of Jimmy Escala: The Court held that alleged inconsistencies between Jimmy Escala's sworn statement and his testimony in court did not impair his credibility. It reiterated the principle that affidavits are generally considered inferior to testimony given in court, being ex parte and often incomplete or inaccurate. The Court emphasized that the appellant did not dispute Escala's presence at the crime scene, and Escala positively identified the appellant as one of the assailants, confirming both the robbery and the stabbing. The Court noted that Escala was an armslength away from the victim and recognized the appellant due to the tricycle's light. On the elements of Robbery with Homicide: The Court found that the elements of the special complex crime of Robbery with Homicide were established. These elements are: (a) the taking of personal property with violence or intimidation; (b) the property belonging to another; (c) the taking characterized by animo lucrandi; and (d) homicide committed by reason or on the occasion of the robbery. The testimony of Escala established that the appellant and his companions held up the victim, took his money (₱50.00), and then the appellant stabbed the victim while his companions held him. The Court clarified that it does not matter whether the killing preceded or followed the taking of property, as long as there is a direct and intimate connection between the robbery and the killing. The abrasions on the victim's head indicated resistance to the taking of his money before the stabbing. On the defense of alibi and denial: The Court found the defense of alibi unmeritorious. For alibi to prosper, the accused must prove not only presence elsewhere but also physical impossibility of being at the locus criminis. In this case, the appellant was within the vicinity of the crime scene. Furthermore, his alibi was not corroborated by his employer, making it a weak defense. The Court held that denial and alibi cannot prevail over the positive identification by a credible witness, especially when the witness was in close proximity to the incident and had the opportunity to observe the assailants.
Main Doctrine
In robbery with homicide, all conspirators are liable as co-principals for the acts of one, even if they did not directly participate in the killing, provided they endeavored to prevent it. The special complex crime of robbery with homicide is established if there is a taking of personal property with violence or intimidation, with intent to gain, and homicide is committed by reason or on the occasion of the robbery. Inconsistencies between an affidavit and testimony do not necessarily impair credibility, especially when the testimony is given in court.