Facts:

The case involves Evangeline Nunag, Tirso V. Delas Armas, and Arnel Zafra, who were charged with Robbery with Homicide and Less Serious Physical Injuries before the Regional Trial Court of Malolos, Bulacan, Branch 6. The incident occurred on February 22, 1988, in Sta. Maria, Bulacan, where the accused allegedly conspired to rob Agueda Santos and Epifania Santos. The information filed by the Assistant Provincial Fiscal detailed that the accused, armed with a piece of driftwood and a knife, attacked Agueda Santos, inflicting serious injuries that led to her death, while Epifania Santos sustained less serious injuries. During the trial, Nunag and Delas Armas pleaded "not guilty," while Zafra remained at large and was not arraigned. Delas Armas later changed his plea to guilty, resulting in a partial judgment against him, but his sentence was suspended due to his minority. Nunag's defense included a motion to subpoena Delas Armas to testify on her behalf, which the ...

Facts:

Background of the Case

Evangeline Nunag, along with Tirso delas Armas and Arnel Zafra, was charged with Robbery with Homicide and Less Serious Physical Injuries under Article 294, paragraphs 1 and 3 of the Revised Penal Code. The crime occurred on February 22, 1988, in Sta. Maria, Bulacan. The accused allegedly conspired to rob the Santos family, resulting in the death of Agueda Santos and injuries to Epifania Santos.

Plea and Partial Judgment

• Tirso delas Armas initially pleaded "not guilty" but later changed his plea to "guilty." The trial court rendered a partial judgment, finding him guilty and committing him to a rehabilitation center due to his minority.
• Arnel Zafra remained at large and was not arraigned.
• Evangeline Nunag pleaded "not guilty" and proceeded to trial.

Prosecution's Evidence

1. Leonides Mateo (laundrywoman for the Santos family):

   • Testified that she saw Nunag, delas Armas, and Zafra enter the Santos house under the pretense of seeking employment.
   • Witnessed Nunag straddling Agueda Santos while delas Armas held a knife.
   • Heard Agueda Santos screaming for help and saw her bloodied on the floor.
   • Delas Armas locked her in the kitchen to prevent her from escaping.

2. Pat. Godofredo Glorioso (police officer):

   • Responded to a robbery call and found Nunag hiding in a nipa hut with a slashed wrist.
   • Recovered money, knives, and a broken wooden figurine from the scene.
   • Nunag admitted that her companions were delas Armas and Zafra.

3. Carlos Santos (husband of Agueda Santos):

   • Testified about the death of his wife and the financial losses incurred.

4. Dr. Benito Caballero (autopsy surgeon):

   • Confirmed that Agueda Santos died from multiple head injuries caused by a hard object, not a bladed weapon.

Defense's Version

• Evangeline Nunag claimed she was unaware of the robbery and only accompanied delas Armas to retrieve his clothes.

• She alleged that delas Armas and Zafra were the ones who attacked Agueda Santos, and she tried to stop them but was pushed away.

• She denied knowledge of the money found in the jacket she was wearing, claiming it belonged to delas Armas.

• Tirso delas Armas testified that Nunag was holding Agueda Santos by the shoulders while she was bloodied, and he fled the scene with Zafra.

Trial Court's Decision

• The trial court found Nunag guilty of Robbery with Homicide and sentenced her to Reclusion Perpetua.
• She was also ordered to pay compensatory and actual damages to the heirs of Agueda Santos.
• The case against Zafra was archived pending his arrest.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Credibility of Witnesses:

   • The testimonies of Leonides Mateo and Tirso delas Armas were consistent and credible. Both described Nunag's position straddling the victim, which corroborated her active participation in the crime.
   • Nunag's claim that delas Armas' testimony was fabricated was unfounded, as she herself sought to have him testify.

2. Conspiracy:

   • The accused acted in concert, pretending to seek employment to gain entry into the Santos house.
   • Their actions, such as cutting the telephone line, locking the maid in the kitchen, and fleeing together, demonstrated a unity of purpose.
   • Under the principle of conspiracy, all participants in the robbery are equally liable for the homicide, even if they did not directly cause the death.

3. Designation of the Crime:

   • The crime committed was Robbery with Homicide, regardless of the injuries inflicted on Epifania Santos. The injuries did not constitute a separate offense but were considered aggravating circumstances.

4. Nunag's Participation:

   • Nunag's act of fleeing to a remote area, slashing her wrist, and possessing stolen money and personal items in the jacket she wore indicated her involvement in the crime.
   • Her claim of innocence was unsupported by evidence and contradicted by the prosecution's witnesses.