People v. Apole
REITERATIONFacts
The Antecedents: On January 23, 2003, at approximately 7:30 PM, five armed men, claiming to be NPA, barged into the house of spouses Yasumitsu Hashiba and Emelie Lopio Hashiba in Barangay Bunga, Lanuza, Surigao del Sur. They divested Emelie of cash and jewelry amounting to ₱30,000.00, and demanded ₱3,000,000.00 in ransom. When Emelie could not produce the full amount, they abducted Yasumitsu Hashiba, taking him to an undisclosed location and holding him for seven days. The accused-appellants, Jovel S. Apole, Renato C. Apole, and Rolando A. Apole, were among those identified by the prosecution witnesses. Procedural History: The Regional Trial Court (RTC), Branch 41 of Cantilan, Surigao del Sur, found accused-appellants Jovel S. Apole, Renato C. Apole, and Rolando A. Apole guilty beyond reasonable doubt of Robbery with Violence Against or Intimidation of Persons by a Band (Criminal Case No. C-368) and Kidnapping for Ransom and Serious Illegal Detention (Criminal Case No. C-369). The RTC sentenced them to suffer the indeterminate penalty for robbery and the death penalty for kidnapping. The Court of Appeals (CA) affirmed the conviction but modified the penalty for kidnapping to reclusion perpetua due to the enactment of Republic Act No. 9346, and adjusted the damages awarded. The Petition: Accused-appellants appealed to the Supreme Court, primarily challenging the credibility of the prosecution witnesses and arguing that the prosecution failed to prove their guilt beyond reasonable doubt.
Issue(s)
Whether the prosecution witnesses' testimonies were credible and sufficient to prove the guilt of the accused-appellants beyond reasonable doubt. Whether the accused-appellants conspired to commit the crimes of robbery by a band and kidnapping for ransom and serious illegal detention. Whether the penalties and damages awarded by the Court of Appeals were proper.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals with modification. The accused-appellants were found guilty of Robbery with Violence Against or Intimidation of Persons by a Band and Kidnapping for Ransom and Serious Illegal Detention. The penalties and damages were modified as follows: 1. In Criminal Case No. C-368 (Robbery by a Band), the accused-appellants were sentenced to suffer imprisonment for Four (4) years and Two (2) months of prision correccional, as minimum, to Ten (10) years of prision mayor, as maximum. They were also ordered to pay ₱78,000.00 as actual damages, ₱50,000.00 as moral damages, and ₱25,000.00 as exemplary damages. 2. In Criminal Case No. C-369 (Kidnapping for Ransom and Serious Illegal Detention), the accused-appellants were sentenced to suffer the penalty of reclusion perpetua, without the possibility of parole. They were also ordered to pay ₱75,000.00 as civil indemnity, ₱75,000.00 as moral damages, and ₱30,000.00 as exemplary damages.
Ratio Decidendi
On the credibility of prosecution witnesses and sufficiency of evidence: The Court reiterated the well-settled rule that the matter of assigning values to declarations on the witness stand is best performed by the trial judge who had the opportunity to observe the witnesses. This assessment, when affirmed by the appellate court, is accorded high respect and is generally binding upon the Supreme Court. The Court found no cogent reason to disturb the findings of fact and judgments of conviction rendered by the RTC and affirmed by the CA. The testimonies of Emelie and Crisologo Hashiba established beyond reasonable doubt the commission of the crimes by the accused-appellants. The Court found the defense's claim that the victim went with them voluntarily due to a treasure map to be a ridiculous attempt to extricate themselves from the offense, noting inconsistencies and lack of logic in their narrative. The Court also rejected the claim that the victim was freely released, stating they released him only after knowing authorities were looking for them and other co-accused were arrested. On conspiracy: The Court found conspiracy among the accused-appellants and their cohorts. Conspiracy exists when two or more persons come to an agreement concerning a felony and decide to commit it, which can be inferred from their acts before, during, and after the commission of the crime. The Court noted their arrival at the victim's home armed, their designated roles upon entry (lookouts, those who divested the victim, those who guarded others), and their subsequent actions in the abduction (Jovel securing ransom, Renato and Rolando guarding the victim). These acts were complementary and geared towards their common objective of extorting ransom. Once conspiracy is established, the act of one is the act of all. On the penalties and damages: For robbery by a band, the Court imposed the penalty of imprisonment for Four (4) years and Two (2) months of prision correccional, as minimum, to Ten (10) years of prision mayor, as maximum, in accordance with Article 294(5) in relation to Article 295 of the Revised Penal Code and the Indeterminate Sentence Law. The Court sustained the awards for actual, moral, and exemplary damages, noting the inherent aggravating circumstance of a band in the commission of robbery. For kidnapping for ransom and serious illegal detention, the Court affirmed the CA's reduction of the penalty from death to reclusion perpetua, citing Republic Act No. 9346. The Court also emphasized that the accused-appellants are not eligible for parole under Section 3 of RA 9346. The Court modified the damages awarded in this case to align with prevailing jurisprudence, awarding ₱75,000.00 as civil indemnity, ₱75,000.00 as moral damages, and ₱30,000.00 as exemplary damages.
Main Doctrine
The Court affirmed the conviction of the accused-appellants for robbery by a band and kidnapping for ransom and serious illegal detention, modifying the penalties and damages awarded. The Court reiterated that the credibility of witnesses is best assessed by the trial court and affirmed by the appellate court, and that conspiracy can be inferred from the collective actions of the accused.