People v. Sumalinog, Jr.
REITERATIONFacts
The Antecedents: On March 29, 1994, at around 9:45 p.m., spouses Domingo and Ma. Victoria Adelan and their two daughters were sleeping in their house. A stranger, later identified as Noel Galvez, was found by their daughter going through drawers. Ma. Victoria Adelan woke her husband, Domingo, who discovered Galvez rifling through his wallet containing approximately P3,000.00. As Domingo Adelan cautiously got out of the mosquito net, he accidentally made a noise, alerting Galvez. Galvez then stabbed Domingo twice. Another man, Dominador Sumalinog, Jr., emerged from behind the kitchen door and also stabbed Domingo. Despite his wounds, Domingo managed to fight back, hitting Galvez on the neck with a bolo. Both assailants fled. Domingo Adelan, bleeding profusely, was brought to various hospitals but succumbed to his wounds while en route to Manila. Ma. Victoria Adelan identified both Galvez and Sumalinog, Jr. in police line-ups. The autopsy revealed multiple stab wounds causing massive hemorrhage. Procedural History: The Regional Trial Court (RTC), Branch 9, Malolos, Bulacan, found Dominador Sumalinog, Jr. and Noel Galvez guilty of Robbery with Homicide and sentenced them to reclusion perpetua. They were ordered to jointly indemnify the heirs of Domingo Adelan. The Petition: Only Dominador Sumalinog, Jr. appealed his conviction.
Issue(s)
Whether the trial court erred in disregarding the defense witnesses' testimonies and relying on the prosecution witnesses. Whether the trial court erred in finding the appellant guilty despite the prosecution failing to prove his guilt beyond reasonable doubt. Whether the trial court erred in awarding excessive moral damages and ordering the appellant to pay an aggregate amount of P662,350.00 to the victim's heirs.
Ruling
The Supreme Court affirmed the conviction of Dominador Sumalinog, Jr. for Robbery with Homicide with modifications to the awarded damages. The penalty of reclusion perpetua was upheld. The Court modified the monetary awards for actual damages, civil indemnity, lost earnings, and moral damages, while deleting the award for attorney's fees.
Ratio Decidendi
On the issue of credibility of witnesses and the trial court's assessment: The Court held that the trial court did not err in giving more weight to the prosecution witnesses' testimonies over the defense witnesses. The defense of alibi is considered the weakest, especially when the corroboration comes from close relatives and not disinterested persons. The Court noted that the defense witnesses' testimonies were aimed at supporting an alibi, which is easily fabricated. Furthermore, the appellant's claimed location during the crime was only four kilometers away from the scene, a distance easily traversable, thus failing the requirement that the accused must be so far away that it was physically impossible for him to be present. The Court also found the defense's explanation for Galvez's neck wound and subsequent actions to be a poorly contrived cover story. On the sufficiency of proof for guilt beyond reasonable doubt: The Court found that the prosecution successfully proved the elements of Robbery with Homicide. The eyewitness account of Mrs. Adelan was crucial, positively identifying both Galvez and Sumalinog, Jr. as the perpetrators who ransacked their room and subsequently stabbed her husband. The Court emphasized that even if the appellant did not directly inflict any injury, his participation in the conspiracy to commit robbery made him liable for the homicide committed on the occasion thereof. The Court reiterated that in conspiracy, the act of one is the act of all, and all participants in the robbery are liable for the death that occurs during its commission. On the award of damages: The Court affirmed the award of P50,000.00 as civil indemnity for the wrongful death. The actual damages for funeral and burial expenses were adjusted to P83,950.00 based on receipts and unobjected testimony. The computation for lost earning capacity was corrected using the standard formula, resulting in an award of P3,112,476.00 based on the victim's income and remaining life expectancy. The moral damages awarded by the trial court were reduced from P250,000.00 to P50,000.00, aligning with current jurisprudence. The award for attorney's fees was deleted for lack of legal basis.
Main Doctrine
The existence of conspiracy makes all perpetrators liable as principals for robbery with homicide, even if they did not directly participate in the killing. Non-flight is not proof of innocence. Alibi is a weak defense, especially when contradicted by credible eyewitness testimony.