G.R. No. 234519 - People vs. Juare y Elisan

The accused-appellants, Reynaldo Juare y Elisan and Danilo Aguadilla y Bacalocos, were charged with the complex crime of Robbery with Homicide under Article 294(1) of the Revised Penal Code.
The Information charged that on or about May 24, 2000, in Navotas, Metro Manila, the accused, armed with a blunt instrument and a bladed weapon, unlawfully and feloniously robbed and fatally stabbed the victim, Adela Abella y De Castro, resulting in her death and the loss of cash and valuable jewelries.

On the evening of May 23, 2000, witnesses testified that only a few persons were present at the Abella residence, including the victim, Juare, Aguadilla, and Alfredo Baudin (the caretaker/house helper).
Circumstantial evidence included:

Testimonies that detailed the entry of Aguadilla into the premises (after being let in by Juare) and his subsequent actions.
The discovery of a pair of shorts bearing bloodstains in Juare’s room.
A kitchen knife, later identified as the victim’s, found in Aguadilla’s house with traces of human blood.

The architecture of the Abella residence was significant, as the doors could only be locked from the inside, implying that any intrusion had to be facilitated by someone within the premises.

Prosecution witnesses included a medico-legal officer who conducted the autopsy, a neighbor (Tecson), the victim’s daughter (Teresita), the caretaker (Baudin), a barangay chairman (Tan), and police investigators, among others.
The testimonies established that:

On the night of the incident, Aguadilla was seen entering the victim’s house, and no one else was reported to have exited before the discovery of the crime.
A blood-stained pair of shorts and a kitchen knife (both linked to the victim) were recovered the following morning, thereby linking the accused to the crime scene.

The defense’s version was that Juare was asleep and merely performed the duty of locking the door, whereas Aguadilla claimed he was only borrowing an umbrella and left after spending time with his companions.

The Regional Trial Court (RTC) held that the circumstantial evidence, although indirect, was sufficient to place the accused at the scene and prove beyond reasonable doubt that they committed robbery with homicide.
Based on the cumulative evidence and the demeanor of the accused during testimony, the RTC convicted Juare and Aguadilla, imposing the penalty of reclusion perpetua and awarding various damages to the victim’s heirs.
The Court of Appeals (CA) affirmed the RTC’s decision, modifying the damage awards in accordance with recent jurisprudence, and underscored the probative value of the circumstantial evidence.

Juare and Aguadilla appealed the verdict.
Upon further review by the Supreme Court, the appeal of Reynaldo Juare was considered, while the appeal concerning Danilo Aguadilla was dismissed on the grounds of his death during the pendency of his appeal.

Whether the combined circumstantial evidence was sufficient to establish, beyond reasonable doubt, that Reynaldo Juare and Danilo Aguadilla were guilty of the complex crime of Robbery with Homicide.

Whether the absence of direct eyewitness testimony undermined the prosecution’s case, given that the circumstantial evidence (bloodstained shorts, the victim’s kitchen knife, and the locking mechanism of the doors) pointed to the presence and conduct of the accused.
Whether the defense’s alibi and denial, which were seen as evasive and unsupported by corroborative evidence, could be given any weight in light of the strong, cumulative circumstantial evidence against the accused.
Whether the trial court’s evaluation of the witness credibility and factual evidence was proper, thereby warranting deference by the appellate court.