Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Alejandro Campos y Armado and Renato de la Cruz y Borac, the accused. The events transpired on August 17, 1989, in Kalookan City, Metro Manila. The accused were charged with robbery with homicide and frustrated homicide after they allegedly attacked and stabbed two women, Felicidad Alfaro and her sister Mercelina Alfaro Jacobe, during a robbery at Maxim's Mini Mart, where they resided. On the night of the incident, Felicidad and Mercelina were preparing to sleep when they were attacked. Felicidad was stabbed multiple times but survived, while Mercelina succumbed to her injuries. The prosecution's case was built on the testimony of Felicidad, who identified Campos as the assailant and recognized de la Cruz standing by the door during the attack. The trial court found both accused guilty and sentenced them to reclusion perpetua, ordering them to indemnify the victims' family for burial...

Facts:

Incident Overview
On August 17, 1989, in Caloocan City, Metro Manila, Alejandro Campos y Armado and Renato dela Cruz y Borac were charged with robbery with homicide and frustrated homicide. The incident involved the stabbing of Mercelina Alfaro Jacobe, who died, and Felicidad Alfaro, who survived. The accused allegedly stole P10,000.00 from the victims.

Victims and Location
Felicidad Alfaro and Mercelina Alfaro Jacobe resided inside Maxim's Mini Mart at Cefel's Park Subdivision, Tala, Novaliches, Caloocan City. The mini mart was adjacent to Cefel's General Merchandise, a hardware store owned by Felipa Jacobe, Mercelina's mother-in-law.

Events Leading to the Crime
On August 16, 1989, at around 10:00 PM, Felicidad and Mercelina prepared to sleep inside the mini mart. Felicidad turned off all lights except the kitchen light. Mercelina slept on the bed with her two-year-old son, Christopher, while Felicidad slept on the floor beside them.

The Attack
At around midnight, Felicidad woke up and was stabbed by Alejandro Campos. She recognized Campos, who frequented their store to buy gas. She also saw Renato dela Cruz standing near the door. Campos then stabbed Mercelina, who was still on the bed. Both accused fled the scene.

Aftermath
Felicidad managed to call for help and was taken to the hospital. Mercelina was pronounced dead on arrival. The next day, Felicidad’s father found a bag containing P10,000.00 empty. The accused were later arrested and identified by Felicidad.

Medical Findings
Dr. Amancio Angustia treated Felicidad, who had multiple stab wounds and a fractured left arm. Dr. Dario Gajardo conducted an autopsy on Mercelina, finding eight stab wounds and internal injuries, with the cause of death being cardio-respiratory arrest.

Defenses of the Accused
Alejandro Campos claimed he was at home during the incident but later admitted to being at the store at the call of dela Cruz. Renato dela Cruz denied involvement, alleging Campos implicated him due to jealousy over his higher salary.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Elements of Robbery with Homicide
   For a conviction of robbery with homicide, the prosecution must prove: (a) the taking of personal property with violence or intimidation; (b) the property belongs to another; (c) the taking is with intent to gain; and (d) homicide occurs on the occasion of the robbery. In this case, the prosecution failed to prove the first three elements conclusively.

2. Conspiracy
   Conspiracy requires an agreement to commit a felony and must be proven beyond reasonable doubt. Mere presence at the scene of the crime is insufficient to establish conspiracy. There was no positive and convincing evidence showing dela Cruz’s active participation in the crime.

3. Presumption of Innocence
   The accused is presumed innocent until proven guilty beyond reasonable doubt. The prosecution’s evidence against dela Cruz was insufficient to overcome this presumption.

4. Credibility of Witnesses
   While Felicidad’s testimony was credible, it did not provide sufficient evidence to convict dela Cruz. Her identification of dela Cruz was unclear due to poor lighting, and she did not witness him committing any overt acts in furtherance of the crime.

Conclusion:

The Supreme Court acquitted Renato dela Cruz due to lack of evidence proving his involvement in the robbery and stabbing. The decision emphasized the importance of proving all elements of a crime beyond reasonable doubt and the presumption of innocence in favor of the accused.