G.R. No. 107383 - Nizurtado vs. Sandiganbayan

On April 19, 2012, at about 9:20 p.m., Herminia Sonon y Bolantes and Marieta Dela Rosa y Apelado were riding a jeepney along Dimasalang Road, Sampaloc, Manila.
A man boarded the jeepney wielding an ice pick, declared a hold-up, and forcibly took the victims’ bags containing cash, personal items, and other belongings.
Immediately after the robbery, the perpetrator disembarked and proceeded to a nearby tricycle where three other men were waiting.

The suspect boarded the tricycle and joined his accomplices as one of them used a gun to further intimidate the passengers.
As the victims and other jeepney passengers alighted and called for help, PO2 Joel Magno y Rivera and Carlo Mijares y Zamora, who were nearby, approached the incident.
In the ensuing commotion, the tricycle driver (who turned out to be Ronald) maneuvered the vehicle back to the scene, thereby facilitating a situation in which one of his companions shot PO2 Magno in the forehead, resulting in the officer’s death.
Following the fatal shooting, the four suspected robbers fled the scene.

A tip-off led the Manila Police District to Blumentritt Street in Sampaloc, where an informant identified one of the suspects as Ronald Laguda y Robidiso, also known as "Bokay".
Ronald was promptly arrested, and both victims along with Carlo confirmed his involvement – specifically noting that he wielded the ice pick during the robbery and was associated with the shooter.
Based on the evidence and testimonies, Ronald was charged with the complex crime of robbery with homicide.

At trial, Ronald pleaded not guilty, claiming that he was with his common-law wife and had an alibi stating he was at a computer shop until early the following morning.
Despite his defense of denial and alibi, the RTC found him guilty beyond reasonable doubt, convicting him of robbery with homicide.
The RTC held that Ronald’s actions—boarding the jeepney, robbing the passengers, and later driving the tricycle to facilitate the shooting of PO2 Magno—fulfilled the elements of the offense.
Ronald was sentenced to reclusion perpetua and ordered to pay significant amounts as civil indemnity, moral damages, exemplary damages, actual damages, and damages for lost income.

Ronald elevated the case to the CA, challenging his warrantless arrest and the ruling that he conspired in committing the homicide.
He asserted that his role was limited to driving the tricycle and that he should be considered an accomplice rather than a principal in the homicide.
Ronald also referenced People v. Illescas, arguing that his involvement did not rise to the level of a conspiracy.
The Office of the Solicitor General, however, maintained that Ronald was a principal actor and played an integral role in ensuring the success of the robbery and the subsequent homicide.

Ronald’s active participation in the robbery where he wielded the ice pick.
His subsequent role in driving the tricycle to position his gun-wielding companion for a clear shot at PO2 Magno.

Multiple testimonies consistently corroborated Ronald’s presence and involvement at the scene, linking him conclusively to both the robbery and the homicide.
The sequencing of events and the collective movement of Ronald and his accomplices were indicative of a planned and concerted criminal effort.

Whether Ronald, along with his three accomplices, acted in concert demonstrating an implicit agreement (conspiracy) to commit robbery with homicide.
Whether the interaction and coordinated actions among the accused inherently established the requisite conspiracy under the law.

The propriety and legal effect of Ronald’s warrantless arrest.
Whether Ronald’s subsequent participation in the trial and failure to object to the arrest prior to arraignment waives any claim regarding the arrest’s legality.

The credibility and sufficiency of Ronald’s alibi and denial.
Whether the uncorroborated defenses offered by Ronald could counterbalance the positive declarations of the prosecution witnesses.
The applicability of precedent cases such as People v. Illescas in determining the nature of his involvement as either principal or mere accomplice.

Whether the sentencing of reclusion perpetua and the penalties imposed, considering the composite elements of the crime, were correctly applied.
The appropriateness of the modifications regarding damages and indemnities ordered on appeal.