People v. Reanzares
REITERATIONFacts
The Antecedents: On 10 May 1994, around 8:10 PM, spouses Gregorio and Lilia Tactacan, owners of a sari-sari store in San Miguel, Sto. Tomas, Batangas, closed their store and boarded their passenger-type jeepney to return home to Barangay San Roque, Sto. Tomas, Batangas. While Gregorio was maneuvering the jeep backwards, two unidentified men suddenly climbed aboard, claiming they were going to the town proper; Lilia informed them they were not passing through there, so they said they would alight at the nearest intersection. After traveling about 500 meters, one hitchhiker pointed a .38 caliber revolver at Gregorio while the other poked a balisong at Lilia's neck, ordering Gregorio to stop. Two other persons, including later-identified accused Armando Reanzares, were waiting nearby; upon stopping, Reanzares and his companion approached, pulled Gregorio to the back, gagged and blindfolded him, tied his hands and feet, and took his Seiko wristwatch worth P2,500. Reanzares then drove the jeepney as instructed. Blindfolded Gregorio heard Lilia pleading for mercy, citing their children and offering all they wanted; after her last plea, a commotion ensued with Lilia crying 'aray!', followed by silence; after three minutes, a voice warned Gregorio not to move, and the culprits fled. Gregorio freed himself, found Lilia dead on the jeepney floor with blood splattered, her bag containing P1,200 cash missing; he rushed her to C.P. Reyes Hospital where she was pronounced dead on arrival. Autopsy by Dr. Lily D. Nunes revealed eight stab wounds on Lilia's chest and abdomen, caused by a sharp pointed object like a long knife, inflicted by more than one person, all fatal except one non-penetrating wound. Lilia was 48 years old, earning P3,430 monthly as a teacher. Procedural History: Two informations were filed against Reanzares and three John Does: one for violation of PD 532 (Highway Robbery with Homicide), alleging conspiracy to rob the wristwatch and cash with homicide; the other for carnapping under RA 6539. Only Reanzares was arrested. At trial, prosecution presented Gregorio's testimony positively identifying Reanzares and Dr. Nunes' medical evidence. Defense presented Reanzares' alibi of being in Barangay Tagnipa, Garchitorena, Camarines Sur, for his daughter's baptism, corroborated by father Jose and brother Romeo, who saw him off to Bicol on 9 May 1994. On 26 May 1997, RTC Tanauan, Batangas (Br. 6, Judge Flordeliza Ozaeta-Navarro) convicted Reanzares of Highway Robbery with Homicide under PD 532, sentencing him to death, ordering payments to Lilia's heirs (P172,000 funeral expenses, P50,000 indemnity, P1,000 cash) and P2,500 to Gregorio for watch; acquitted of carnapping for insufficiency of evidence. Case elevated on automatic review. The Petition: Accused-appellant argued insufficiency of evidence, challenging Gregorio's credibility: initial failure to name him to police, public plea for identification via newspaper, refusal of lie-detector test, and suppression of witnesses Renato and wife who saw culprits flee. He asserted alibi: in Bicol for daughter's baptism on 10 May 1994, corroborated by family; claimed physical impossibility of presence at crime scene. Insisted conviction under PD 532 erroneous without proof beyond reasonable doubt.
Issue(s)
Whether the accused's guilt for Highway Robbery with Homicide under PD 532 was proved beyond reasonable doubt, considering challenges to eyewitness identification and alibi defense. Whether the proper crime is Highway Robbery with Homicide under PD 532 or Robbery with Homicide under RPC Art. 294(1). Whether the awarded damages were properly computed and substantiated.
Ruling
The Decision of the RTC is MODIFIED: Accused is GUILTY of Robbery with Homicide under Art. 294(1), RPC (as amended), sentenced to reclusion perpetua; ordered to pay heirs of Lilia: P50,000 indemnity, P50,000 moral damages, P1,200 actual (cash), P438,971.40 loss of earning capacity, P22,000 funeral expenses. Costs de oficio.
Ratio Decidendi
On Issue 1 (Guilt, Identification, and Alibi): Gregorio Tactacan's testimony was categorical, straightforward, spontaneous, frank, and consistent on cross-examination, positively identifying Reanzares as one of the waiting culprits who approached the jeepney, establishing his participation beyond reasonable doubt. The delay in naming Reanzares to police was reasonably explained by fear for family safety after neighbors reported lurkers and advice to withhold names until after burial, not indicative of fabrication; no ill motive existed, and as grieving husband, he had motive to pursue true culprits. Refusal of lie-detector test is irrelevant as such tests are inadmissible in Philippine courts, their results inconclusive. Alleged suppression of Renato and wife as witnesses invokes disputable presumption under Rule 131, Sec. 3(e), Rules of Court, but inapplicable as they were equally available to defense. Alibi fails both prongs: accused not proven present elsewhere (family only saw him off to Bicol, no proof of arrival or stay; possible to alight early, commit crime, proceed later), and no physical impossibility given proximity (Sto. Tomas, Batangas to Camarines Sur feasible within timeframe). Positive identification by victim prevails over weak alibi, per People v. Sumalde (G.R. No. 121780, 17 March 2000). On Issue 2 (Proper Crime): PD 532 requires proof of organization for indiscriminate highway robberies, per People v. Puno (219 SCRA 85), People v. Mendoza (254 SCRA 61), People v. Versoza (294 SCRA 466); here, only single robbery against Tactacans proven, no prior/similar acts or syndicate evidence, thus not PD 532 whose aim is deterring widespread depredations stunting progress. Facts fit robbery with homicide under RPC Art. 294(1): taking with violence/intimidation (watch, cash) with homicide on occasion thereof; information's description controls over title, per Socrates v. Sandiganbayan (253 SCRA 773) citing People v. Maravilla. Committed post-RA 7659 (31 Dec 1993), penalty reclusion perpetua to death; no modifiers, thus lesser penalty reclusion perpetua per Art. 63(2), RPC. On Issue 3 (Damages): P50,000 indemnity sustained (standard for death); add P50,000 moral damages for bereavement. Loss of earning capacity: life expectancy 2/3(80-48)=21.33 years; gross annual P41,160 (P3,430 x 12), deduct 50% living expenses (P20,580 net), total P438,971.40, per People v. Estepano (G.R. No. 126283, 28 May 1999). Actual: cash to P1,200 (proven); funeral to P22,000 (substantiated, excess unsupported per People v. Manlapaz citing People v. Gutierrez); watch P2,500 deleted (no receipt, self-serving valuation; courts cannot judicially notice jewelry value per People v. Paraiso citing People v. Marcos).
Main Doctrine
Conviction under PD 532 for highway robbery with homicide necessitates proof that the accused were organized for the purpose of committing robbery indiscriminately against travelers on highways, as its objective is to deter lawless elements disturbing peace through repeated depredations. A single isolated act of robbery with homicide against specific victims, even on a highway, does not fall under PD 532 but constitutes the special complex crime of robbery with homicide under Article 294(1) of the Revised Penal Code, as amended by RA 7659, where the controlling factor is the description of the offense in the information rather than its title. For alibi to prosper, it must be established that the accused was at another place at the time of the offense and that it was physically impossible for him to have been at the crime scene, a quantum not met by mere testimony of departure without proof of arrival at destination. The positive, categorical identification by a credible eyewitness, especially a victim with no ill motive, prevails over alibi, particularly when the delay in naming the accused is reasonably explained by fear for family safety. In the absence of aggravating or mitigating circumstances, the penalty for robbery with homicide is the lesser indivisible penalty of reclusion perpetua under Article 63(2) of the RPC. Damages for wrongful death include P50,000 civil indemnity, P50,000 moral damages, computed loss of earning capacity using the formula [2/3 x (80 - age)] x [gross annual income - 50% living expenses], and only substantiated actual damages like proven funeral expenses.