Manangan v. People
REITERATIONFacts
The Antecedents: On February 5, 2001, in Tumauini, Isabela, Ben Manangan (petitioner) and several unidentified individuals allegedly committed robbery by a band. The accused, armed with firearms and wearing masks, entered the house of Ocampo Denna and his wife Jolita Denna. They forced the victims to give them ₱50,000.00 under threat of death. Jolita Denna positively identified Ben Manangan, who was not wearing a mask, as part of the group. Fortunata Denna also identified Ben Manangan, noting he was unmasked while others wore masks and jackets. Procedural History: The Regional Trial Court (RTC) of Cabagan, Isabela, Branch 22, found petitioner guilty of robbery by a band and sentenced him to an indeterminate prison term. The RTC denied petitioner's Motion for New Trial. The Court of Appeals (CA) affirmed the RTC decision with modification, reducing the penalty. The CA denied petitioner's motion for reconsideration. The Petition: Petitioner filed a petition for review on certiorari seeking to reverse the CA's decision, raising issues regarding implied conspiracy, proof of corpus delicti, and the denial of his Motion for New Trial.
Issue(s)
Whether or not the Court of Appeals gravely erred in affirming the decision of the RTC in finding, based on its "honest belief," that there was "implied conspiracy"; Whether or not the corpus delicti was proven beyond reasonable doubt by the prosecution; and Whether or not the denial of the Motion for New Trial by the RTC was proper.
Ruling
The petition is denied. The Decision of the Court of Appeals affirming the conviction of Ben Manangan for robbery by a band is affirmed.
Ratio Decidendi
On the issue of implied conspiracy: The Court reiterated that conspiracy must be established with the same quantum of proof as the crime itself and must be shown as clearly as the commission of the crime, not merely based on the trial court's "honest belief." However, in cases of robbery by a band, the law presumes the attendance of conspiracy. Any member of a band present at the commission of a robbery by the band is punished as a principal, unless they attempted to prevent it. The positive identification of the petitioner by eyewitnesses, coupled with the circumstances of the commission of the crime, sufficiently established his participation and implied conspiracy with the other members of the band. On the issue of corpus delicti: The Court held that the corpus delicti of robbery by a band was sufficiently established through direct evidence, specifically the testimonies of the two eyewitnesses who were present at the scene of the crime. They testified to seeing a group of armed and masked men, including the unmasked petitioner, enter their house, rob them of ₱50,000.00 at gunpoint, and leave. The elements of robbery by a band were proven: petitioner was a member of a band (more than three armed malefactors), he was present at the commission of the robbery, an assault (use of force and threats) was committed by the band, and petitioner did not prevent the assault. On the denial of the Motion for New Trial: The Court found the RTC's denial proper. The evidence sought to be presented by the petitioner, through his wife and six other persons, was not newly discovered evidence but rather "forgotten evidence." These witnesses were available at the time of trial and lived in the same barangay. Their testimonies would merely corroborate the petitioner's alibi, which was already considered and found unmeritorious against the positive identification by the eyewitnesses. The evidence was not material enough to alter the outcome of the judgment, and reasonable diligence would have allowed their discovery and production during the trial.
Main Doctrine
The existence of conspiracy in robbery by a band is presumed, and conspiracy need not be proven as long as the existence of a band is clearly established. Furthermore, the defense of alibi cannot prevail over positive identification by prosecution witnesses unless it is shown that physical impossibility prevented the accused from being at the scene of the crime.