G.R. No. 74938-39 - Malaba vs. Gaw Ching

The case involves appellants Alvin J. Labagala and Romeo Labagala, charged with the crime of robbery with homicide.
The offense is detailed in an Amended Information dated December 23, 2002, which alleges that on June 12, 2002, the accused, armed with a deadly weapon, committed a robbery during which they also killed the victim, Mario P. Legaspi, Sr.
The charge includes qualifying circumstances of treachery, use of superior strength, and premeditation as the accused employed means to weaken the victim’s defense.

According to the prosecution, the crime occurred at the victim’s residence in Cabanatuan City during the early evening.
Witness Jun Alberto, who was present at the scene, testified that:

The victim was having dinner under a mango tree when Salve A. Pascual entered the yard.
Four men entered the premises, two of whom were positively identified as Alvin and Romeo Labagala.
Alvin Labagala was seen poking a gun at the victim, whipping him with the weapon, and subsequently taking the victim’s jewelry (including two rings, a necklace, and a wristwatch).
The victim was then dragged inside the house, where a commotion followed and the victim was eventually found dead.

The evidence largely depended on the detailed, positive, and credible testimony of Jun Alberto.
The prosecution argued that the accused acted in a concerted manner, effectively demonstrating that their primary intent was robbery and that the homicide was incidental to achieving that end.
The identifiable acts—weapon use, the act of holding the victim in place, and the subsequent murder—were presented as clear evidence of the accused’s coordinated criminal design.

Romeo Labagala asserted that he was in Barangay Dicos, Nueva Ecija, engaged in harvesting “palay” during the time of the incident.
Alvin Labagala stated that on June 12, 2002, he was in Tanza, Navotas helping friends sell vegetables, and later returned to Guimba, Nueva Ecija.

Both defenses sought to distance the accused from the events in Cabanatuan City.

The Regional Trial Court (RTC) in Branch 27, Cabanatuan City, found the accused guilty beyond reasonable doubt of robbery with homicide under Article 293 in relation to Article 294, paragraph 1, of the Revised Penal Code.
The RTC based its decision on:

The clear and straightforward testimony of Jun Alberto identifying the accused.
The demonstration of mutual aid and conspiracy among the accused during the commission of the crime.

The RTC sentenced the appellants to reclusion perpetua and imposed additional orders for the return of the victim’s jewelry and payment of civil, moral, and temperate damages.
The case against some co-accused was archived, and alias warrants were issued against them.

Allegations that the elements of robbery with homicide were not sufficiently proven.
The contention that the testimony of a single witness was uncorroborated.

The Court of Appeals (CA) affirmed the RTC’s judgment in its June 27, 2014 Decision, underscoring the credibility of the eyewitness evidence and the establishment of conspiracy among the accused.
The CA maintained that the overarching intent was robbery with the homicide being incidental, and it upheld the evidentiary findings of the trial court.
While upholding the convictions, the CA modified the award of damages, increasing the amounts for civil indemnity, moral damages, temperate damages, and adding exemplary damages.

Whether the prosecution was able to prove beyond reasonable doubt all the elements of the crime of robbery with homicide, despite the eyewitness testimony being uncorroborated by another witness.

Whether appellants and their co-accused (who remain at large) acted in conspiracy in committing the crime, thereby sharing equal liability even if one or more did not directly participate in the killing.