Case Digest (G.R. No. 246580)
Facts:
On October 11, 2012 at around 6:00 a.m. in Marikina City, respondents Ronilee Casabuena y Francisco and Kevin Formaran y Gilera, together with their co-conspirator Jimmy Arizala, boarded a jeepney bound for Montalban. Armed with a firearm and bladed weapons and acting in concert, they declared a hold-up and forcibly took wallets, cellphones, ATM cards, and other personal effects from passengers, including Ciara Kristle V. Abella. After the robbery, all three alighted. A bystander alerted PO2 Ramilo P. De Pedro and PO2 Michael Albania, who were on patrol nearby. While attempting to apprehend the suspects, a scuffle ensued over Arizala’s pistol; De Pedro gained control of the weapon and fired twice, killing Arizala. Casabuena and Formaran were arrested, identified by victims at the precinct, and charged under Article 294(1) of the Revised Penal Code for the complex crime of robbery with homicide. At trial, the Regional Trial Court (RTC) found both guilty and imposed the penalty ofCase Digest (G.R. No. 246580)
Facts:
- Criminal Episode
- On October 11, 2012, in Marikina City, Ronilee Casabuena y Francisco and Kevin Formaran y Gilera, together with Jimmy Arizala, boarded a passenger jeepney and declared a hold‐up.
- Armed with a firearm and bladed weapons, they intimidated passengers and forcibly took wallets, cellphones, a pouch bag, ATM cards, and other personal belongings valued at approximately ₱13,020.
- Police Intervention and Aftermath
- Around 6:20 a.m., PO2 Ramilo De Pedro and PO2 Michael Albania, on patrol, responded to a passenger’s call for help and chased the suspects.
- In the ensuing struggle, Arizala produced a pistol; PO2 De Pedro wrestled it away and fired twice, fatally wounding Arizala. The two remaining suspects (appellants) discarded their knife and were arrested.
- A “Sinumpaang Salaysay sa Pag-aresto” was executed by the arresting officers; stolen items were recovered.
- Procedural History
- Appellants pleaded not guilty at arraignment and offered alibi defense, claiming they were innocent passengers mistakenly identified.
- The Regional Trial Court (RTC) found the prosecution witnesses—particularly eyewitness Ciara Kristle Abella and PO2 De Pedro—credible, established conspiracy, and convicted appellants of the special complex crime of robbery with homicide (Art. 294(1), RPC), imposing reclusion perpetua.
- The Court of Appeals affirmed the RTC decision by Decision dated July 25, 2018.
- Appellants filed a petition for review before the Supreme Court, contesting:
- The absence of a direct relation between the robbery and homicide;
- The insufficiency of proof of conspiracy.
Issues:
- Whether appellants are guilty of the complex crime of robbery with homicide under Article 294, paragraph 1 of the Revised Penal Code.
- Whether conspiracy between appellants and Arizala was duly proven.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)