People v. Reyes
REITERATIONFacts
The Antecedents: On October 12, 1997, at approximately 2:00 a.m., PO1 Eduardo C. Molato, while off-duty, witnessed two persons robbing and stabbing Donaldo Salmorin, Jr. y Solis. One assailant took the victim's wristwatch while the other stabbed him at the back. PO1 Molato fired a warning shot, causing the assailants to flee. He hailed a tricycle to take the victim to the hospital and then pursued the suspects, but they escaped. Procedural History: The Regional Trial Court of Malabon, Metro Manila, Branch 72, found accused-appellant Danilo Reyes y Batac guilty beyond reasonable doubt of Robbery with Homicide and sentenced him to suffer the penalty of reclusion perpetua. He was also ordered to pay the victim's father P50,000.00 as death indemnity, P50,000.00 as moral damages, and P47,000.00 as actual damages. The Petition: Accused-appellant appealed the RTC decision, arguing that his guilt was not established beyond reasonable doubt, specifically questioning the proof of animus lucrandi, ownership of the stolen property, and conspiracy. He also challenged the credibility of PO1 Molato's testimony.
Issue(s)
Whether the guilt of the accused-appellant was established beyond reasonable doubt for the crime of Robbery with Homicide. Whether the element of animus lucrandi was sufficiently proven. Whether the ownership of the stolen wristwatch was adequately established. Whether conspiracy was proven. Whether the testimony of PO1 Eduardo C. Molato was credible and sufficient for conviction.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellant guilty beyond reasonable doubt of Robbery with Homicide. The Court upheld the sentence of reclusion perpetua and the civil liabilities imposed.
Ratio Decidendi
On Whether the guilt of the accused-appellant was established beyond reasonable doubt for the crime of Robbery with Homicide: The Court reiterated that a conviction for robbery with homicide requires proof of the taking of personal property with violence or intimidation, the property belonging to another, the taking done with animus lucrandi, and that on the occasion of the robbery or by reason thereof, homicide was committed. The Court found that the established facts clearly constituted robbery with homicide, giving great respect to the factual findings of the trial court. The Court emphasized that the victim was killed on the occasion or by reason of the robbery, thus fitting the definition of the special complex crime under Article 294(1) of the Revised Penal Code. On Whether the element of animus lucrandi was sufficiently proven: The Court held that animus lucrandi or intent to gain, being an internal act, can be established through overt acts. The presumption of intent to gain arises from the furtive taking of useful property pertaining to another, unless special circumstances indicate a different intent. In this case, the act of taking the victim's wristwatch by one accused while the other poked a knife behind him sufficiently gave rise to this presumption. The unlawful taking itself presumes the intent to gain. On Whether the ownership of the stolen wristwatch was adequately established: The Court dismissed the argument that the ownership of the wristwatch was not proven, stating that the detailed narration of the forcible taking and stabbing could not be lightly dismissed by mere conjecture. Furthermore, the Court clarified that in robbery, it is not necessary that the person dispossessed be the owner; actual possession by the victim suffices. The phrase "belonging to another" in Article 293 of the Revised Penal Code merely requires that the property taken does not belong to the offender. The Court noted that robbery can even be committed against a bailee or a thief. On Whether conspiracy was proven: The Court found that conspiracy was clearly manifested in the concerted efforts of the accused-appellant and his cohort. Conspiracy need not be proven by direct evidence of an actual planning; it can be deduced from the mode and manner of the commission of the offense or inferred from the acts of the accused evincing a joint or common purpose and design. The simultaneous acts of forcibly taking the victim's wristwatch and stabbing him indicated a joint purpose, concerted action, and community of interest, thus establishing conspiracy. On Whether the testimony of PO1 Eduardo C. Molato was credible and sufficient for conviction: The Court found no reason to doubt the credibility of PO1 Molato. Regarding the victim's reaction to flee, the Court stated that people react differently to frightening situations, and the warning shot might have caused the victim's behavior. Minor inconsistencies in PO1 Molato's testimony regarding the events after the chase were deemed trivial and even served to strengthen his credibility by showing his testimony was not rehearsed. The Court affirmed that the testimony of a single credible witness is sufficient for conviction, and the positive identification of the accused-appellant by PO1 Molato prevailed over the defenses of alibi and denial.
Main Doctrine
The crime of robbery with homicide is committed when personal property is taken from another with violence or intimidation, with intent to gain, and on the occasion of the robbery or by reason thereof, homicide is committed. Conspiracy may be deduced from the concerted acts of the accused.