G.R. No. 243984 - People vs. Agan

Accused-appellant McMervon Delica Agan, known by aliases “Butchoy” and “Sadisto,” was charged with the special complex crime of Robbery with Homicide under Article 294(l) of the Revised Penal Code (RPC).
The crime occurred on or about November 24, 2008, in Las PiAas City, BF Resort Village, where the accused allegedly targeted a store, stealing cash and fatally stabbing two victims.

The Amended Information (dated March 4, 2010) linked Agan to the robbery where P20,000.00 in cash, kept inside the store for use by the victim’s daughter, Maricar, was taken.
Concurrently, during the robbery, Agan is alleged to have committed homicide by stabbing:

At arraignment on May 25, 2010, Agan pleaded not guilty, and the case proceeded through pretrial and trial phases.

Ricardo Mandreza, the father of the minor victim, who later provided a detailed account of discovering the robbery and the aftermath.
Christian Reyes, who observed Agan “tinkering” with the door lock before the incident, indicating suspicious behavior and possible premeditation.
Mabellen Manibale, whose account noted Agan’s hurried movements from the scene and his evasive responses when approached by bystanders.
Jammy Boy Mendoza, who saw Agan leaving the scene amidst distressing screams and witnessed the chaos at the store.
Dr. Voltaire P. Nulud, whose autopsy report established that fatal stab wounds—especially one that lacerated the left ventricle—were the proximate cause of death.

Agan was seen at or near the scene at critical moments before, during, and after the commission of the crime.
His actions—tampering with the door, fleeing the scene, and subsequently changing his attire—were viewed as indicators of guilt and an attempt to eliminate evidence.

Documentary evidence included receipts of hospitalization and funeral expenses provided by Ricardo Mandreza, further substantiating the financial loss resulting from the crime.

The Regional Trial Court (RTC) of Las PiAas City, Branch 254, convicted Agan as it found that the circumstantial evidence sufficiently established each element of the charged offense beyond reasonable doubt.
The Court of Appeals (CA) in its decision dated February 27, 2018, affirmed the RTC’s findings with modifications:

The CA upheld the conviction based on the cumulative circumstantial evidence.
The CA modified the award of actual damages, correctly allocating expenses to the respective victims’ heirs.

Ultimately, Agan was sentenced to suffer the penalty of reclusion perpetua without eligibility for parole and was ordered to pay various amounts as civil indemnity, moral damages, exemplary damages, temperate damages, and actual damages with interest.

Whether the Court of Appeals erred in convicting Agan of the special complex crime of Robbery with Homicide based solely on circumstantial evidence.

The unlawful taking of personal property using violence or intimidation.
The prosecution’s ability to prove the defendant’s intent (animus lucrandi) to commit robbery.
The occurrence of homicide in connection with the robbery.

Whether Agan’s mere denial of the charges, without any substantive evidence to counter the circumstantial chain, could be deemed a weak or self-serving defense.