People v. Labagala
REITERATIONFacts
The Antecedents: On June 12, 2002, at around 7:30 p.m., in Cabanatuan City, appellants Alvin J. Labagala and Romeo Labagala, along with co-accused Pablito Palens, Salve A. Pascual, and Michael Doe, were charged with robbery with homicide. The Amended Information alleged that the accused, armed with a deadly weapon, with intent to gain and by means of force, violence, and intimidation upon Mario P. Legaspi, Sr., conspired to take jewelry and cash amounting to ₱200,000.00, and on the occasion of the robbery, attacked and killed the victim, inflicting serious physical injuries that caused his death. The Information also alleged treachery, abuse of superior strength, and evident premeditation. Procedural History: Upon arraignment, appellants pleaded not guilty. The prosecution presented Jun Alberto, an eyewitness, who testified that he saw Alvin poke a gun at the victim and whip him with it while the other three held the victim. Alvin then took the victim's jewelry. Jun witnessed the victim being dragged inside the house by Alvin, heard a commotion and moaning, and upon entering the house, found the victim dead. The defense presented denial and alibi from both appellants. The Regional Trial Court (RTC), Branch 27, Cabanatuan City, convicted Alvin and Romeo Labagala of robbery with homicide, sentencing them to reclusion perpetua. Salve Pascual was acquitted, and the cases against Pablito and Michael were archived. The RTC found conspiracy among the appellants and rejected their defenses. The Court of Appeals (CA) affirmed the RTC Decision in toto, finding that the overriding intention was robbery and the killing was incidental thereto, and upholding the credibility of Jun's testimony and the existence of conspiracy. The Petition: Appellants appealed to the Supreme Court, raising issues on whether the prosecution sufficiently proved the elements of robbery with homicide based on uncorroborated testimony and whether conspiracy was established.
Issue(s)
Whether the prosecution sufficiently proved the elements of the crime of robbery with homicide, considering that the eyewitness testimony was uncorroborated. Whether the appellants, together with their co-accused, acted in conspiracy in committing the crime charged.
Ruling
The appeal is unmeritorious. The Supreme Court affirmed the decision of the Court of Appeals, upholding the conviction of Alvin J. Labagala and Romeo Labagala for robbery with homicide. The Court modified the awards of damages, increasing civil indemnity and moral damages to ₱75,000.00 each, temperate damages to ₱50,000.00, and awarding exemplary damages of ₱75,000.00. All damages are to earn interest at 6% per annum from finality of the decision.
Ratio Decidendi
On the issue of whether the prosecution sufficiently proved the elements of robbery with homicide: The Court held that all elements were proven. The elements are: (a) the taking of personal property with violence or intimidation; (b) the property belongs to another; (c) intent to gain; and (d) homicide committed on the occasion or by reason of the robbery. The Court found that the testimony of the sole eyewitness, Jun Alberto, was positive, credible, and sufficient to sustain conviction, despite being uncorroborated. The Court reiterated that the testimony of a single witness, if credible, is enough. The Court also deferred to the trial court's factual findings on witness credibility, which were affirmed by the CA, finding no arbitrary or unfounded basis. The prosecution established the taking of jewelry by force and intimidation, with intent to gain, and that the victim's death occurred on the occasion of the robbery. The Court emphasized that the original criminal design must be to commit robbery, with the killing being incidental. On the issue of whether the appellants acted in conspiracy: The Court affirmed the finding of conspiracy. The Court explained that an accused participating as a principal in robbery is liable for robbery with homicide even without directly participating in the killing, unless they endeavored to prevent it. The records showed that the appellants, with their co-accused, entered the victim's yard, took personal effects by force with intent to gain, and cooperated to achieve this purpose. The eyewitness testified that while Alvin Labagala was assaulting the victim, the other companions were holding the victim in place, demonstrating unity in execution and mutual aid. Since it was not shown that the appellants attempted to prevent the killing, they are both liable as principals for the crime of robbery with homicide.
Main Doctrine
In robbery with homicide, all those who participated as principals in the robbery are liable as principals of robbery with homicide, even if they did not directly participate in the killing, unless they endeavored to prevent it. Conspiracy to commit robbery with homicide makes all conspirators liable as principals.