G.R. No. 118670 - People vs. De Guzman

The accused – Renato de Guzman, Marciano Ramos, Frederick Mosqueda, and Paquito Ancheta – were charged with robbery with homicide as stipulated in the Information dated January 26, 1993.
The crime involved a planned robbery with homicide against Dr. Amadeo Belmonte and Teresa Hape, which resulted in the killing of both victims.
Although four accused were charged, only de Guzman, Ramos, and Mosqueda were initially apprehended; Ancheta remains at-large.
At arraignment, the accused entered pleas of "not guilty," with Mosqueda later discharged and used by the prosecution as a state witness.

In September 1992, Dr. Belmonte and his wife Maria Regina engaged de Guzman, a welder, to construct and install a water tank at their residence in Loakan, Baguio City.
Conflict arose on October 27, 1992, when de Guzman, having hired Frederick Mosqueda as a sub-contractor, sought an additional P2,000.00 for paint, which was refused by the Belmontes leading to de Guzman’s anger.
During a drinking spree in November 1992, de Guzman, along with Mosqueda, Ancheta, and an additional conspirator (later joined by Ramos), planned to break into the Belmonte residence with an intent to kill.
On November 28, 1992, while the Belmonte couple was away, the conspirators commenced their plan.
On the evening of December 2, 1992, de Guzman, Ancheta, and Ramos executed their plan by going to the Belmonte residence; Mosqueda served as look-out but was inadvertently left behind in the ensuing haste.
Evidence of the tactic includes details such as the staged pretext of delivering the water tank and the hurried escape which left Mosqueda isolated from the other co-accused.

On December 3, 1992, the bodies of Dr. Belmonte and Teresa Hape were discovered with evident signs of a struggle—Dr. Belmonte’s body was found hanging with evidences of strangulation, multiple stab wounds, and a gunshot, while Hape's body showed signs of ties, stab wounds, and asphyxia.
The incident came to light following an observation by Marilyn Serran, who noticed a white Kia car and items inside that led to a police investigation.
Accused-appellant Ramos, a police officer stationed in Pozorrubio, Pangasinan, was implicated after being identified by Mosqueda during a police line-up, despite his alibi defense.
De Guzman later testified about an alternative scenario involving other persons (Edwin and Benny) allegedly present at the scene, but his account was met with inconsistencies and did not exonerate him.
The prosecution’s evidence was bolstered by the detailed and corroborated testimony of Mosqueda (despite being discharged), as well as corroborative evidence from police officers and other witnesses such as Marilyn Serran and SPO1 Manuel Francisco.

On December 21, 1994, the Regional Trial Court of Baguio City, Branch 7 rendered a decision finding de Guzman and Ramos guilty beyond reasonable doubt of robbery with homicide, imposing reclusion perpetua along with accessory penalties.
A subsequent order detailed the restitution of stolen items and the award of damages (civil aspect) for the legal heirs of the victims, including awards for loss of earnings, actual damages, moral damages, and exemplary damages.
While de Guzman later filed and succeeded in an Urgent Motion to Withdraw Appeal, the appeal of accused-appellant Ramos remained a subject for review in higher courts.

Accused-appellant Ramos contended that the trial court erred in granting the motion to discharge Mosqueda so that he could testify as a state witness.
Specific challenges included:

The alleged failure to establish an absolute necessity for Mosqueda’s testimony.
The contention that direct evidence was available aside from Mosqueda’s circumstantial account.
The assertion that Mosqueda, as part of the conspiracy, should be held equally culpable and hence not be granted discharge.

The Sufficiency of the Prosecution’s Evidence to Convict Ramos Beyond Reasonable Doubt

Ramos argued that, without relying on Mosqueda’s testimony, the remaining evidence (primarily from eyewitnesses and other police testimonies) was insufficient to establish his guilt beyond reasonable doubt.
His defense also rested on an alibi, claiming he was on duty in Pozorrubio during the commission of the crime, a claim that was rebutted by the prosecution’s evidence.