G.R. No. 220902 - Republic vs. San Lorenzo Development Corporation

On July 19, 1995, an Information was filed before the RTC of Cadiz City, Negros Occidental, Branch 60, charging Rene Baron y Tangarocan (appellant), Rey Villatima, and alias "Dedong" Bargo with the special complex crime of robbery with homicide committed against Juanito Berallo.
The Information alleged that on the evening of June 28, 1995, at Hda. Sta. Ana, Brgy. Burgos, Cadiz City, the accused, conspiring with evident premeditation, treachery, and intent to kill, attacked and stabbed Berallo to death in order to rob him of several items – notably a tricycle sidecar, a motorcycle, a wallet containing cash, a wrist watch, and a ring.
Detailed descriptions of the injuries inflicted on the victim were recorded, including multiple stab and incised wounds with specific measurements and locations, which collectively resulted in severe hemorrhage and death.

Around 8:30 p.m. on June 28, 1995, witness Ernesto Joquino, Jr. observed the victim parking his tricycle in front of Julie’s Bakeshop while engaging in conversation with Canni Ballesteros.
The appellant approached the victim and requested a ride to Hacienda Caridad for a fee, allegedly enlisting the help of co-accused Rey Villatima (then notably wearing a fatigue jacket) and alias "Dedong" Bargo.
A passenger, Pacita Caratao, also observed the victim in the tricycle with the accused riding together and noted the unusual circumstances.

On June 29, 1995, SPO2 Jude dela Rama and his team responded to a report of robbery with homicide and located Berallo’s body in a sugarcane plantation near the highway. Key physical evidence found at the scene included footprints, a tricycle sidecar, a recovered fatigue jacket, and other items matching the description given by the witness testimonies.

The appellant had admitted to being part of the ride in the victim’s tricycle and acknowledged going to hide the stolen motorcycle in Barangay Oringao, Kabankalan, at the house of Rey Villatima’s aunt, Natividad Camparicio.
Physical evidence – such as the recovered fatigue jacket from the crime scene, traces of footprints in the sugarcane plantation, and the eventual recovery of the stolen motorcycle – corrobored the eyewitness accounts.
Nemia Berallo positively identified the motorcycle as belonging to the victim and testified regarding other stolen items.

Despite the lack of direct eyewitness identification linking all accused to the act of killing, circumstantial evidence was relied upon to infer the complicity and conspiracy of the accused in the commission of the crime.

Only the appellant was apprehended whereas Villatima and Bargo remained at-large.
The appellant entered a plea of “not guilty” during arraignment.
Trial proceedings involved presentation of cumulative circumstantial evidence indicating the participation of the appellant alongside his co-accused, leading to a verdict finding him guilty beyond reasonable doubt of robbery with homicide.

Whether the chain of circumstantial evidence presented by the prosecution was sufficient to establish a conviction for robbery with homicide beyond reasonable doubt.

Consideration was given to whether the cumulative evidence, despite the absence of direct eyewitness identification, showed an unbroken chain leading to the necessary moral certainty of guilt.

Whether the appellant’s claim of acting under the irresistible force or uncontrollable fear of an equal or greater injury constitutes an exempting circumstance.

Analysis focused on whether the alleged threat was genuine, imminent, and of such a magnitude that it left the appellant with no opportunity to escape.
Whether the evidence supported the contention that the appellant acted under compulsion rather than as a willing participant in the conspiracy.

Whether the actions of the appellant, including his deliberate decision to remain in the tricycle and later accompany his co-accused to hide the stolen property, indicated complicity in the crime.