G.R. No. 220761 - People vs. Olazo

In July and August 2004, a group of accused persons—including Rogelio Lasconia, Rommel Escobio, accused-appellant Miguel Corbis, and Charito Fernandez—met on several occasions to plan a robbery.
The plan involved robbing the spouses Erlinda and Nicanor Vallecera in their residence at Barangay Bito, Abuyog, Leyte.
Accused Dionesia Lasconia, a household help working for the Vallecera couple, was enlisted to provide covert access by leaving the back gate open.
During the initial meetings, the group’s composition fluctuated; at one meeting, only Rogelio Lasconia, Rommel Escobio, and Miguel Corbis were present, while in another meeting Charito Fernandez also attended.
The early attempts to execute the plan were deferred due to the absence of key members and superstitious omens.

Despite it being a Sunday and Dionesia’s rest day, she reported to the Vallecera residence around 5:00 p.m. to perform her usual chores, such as feeding chickens, sweeping, and cooking.
As agreed, she left the back gate open to allow the co-accused to enter without suspicion.
Around 7:00 p.m., upon hearing suspicious sounds at the back of the house, Dionesia opened the kitchen door to admit three intruders—Rogelio Lasconia, Rommel Escobio, and Eddie Fernandez—all wearing masks.
The intruders assembled near the kitchen area while the spouses were inside the master’s bedroom.
When Erlinda Vallecera eventually emerged, she was accosted:

Accused Eddie Fernandez pointed a gun at her and forcibly grabbed her.
The trio covered her face and coerced her into silence, with Rogelio whispering instructions that they were solely there for money.

They dragged Erlinda into the master’s bedroom and proceeded to hogtie Nicanor Vallecera.
The robbers then forced Erlinda to open a vault and proceeded to seize at least one hundred thousand pesos in cash and numerous pieces of jewelry, even raiding an office for additional valuables.
Following the robbery:

Eddie Fernandez and Rommel Escobio escorted Erlinda to a comfort room.
In the comfort room, Rommel Escobio slashed her throat with a samurai sword found in Erlinda’s office.
Rogelio Lasconia later re-entered the room and stabbed her several times in the neck with a long knife, causing fatal wounds.

To cover the crime, the accused then hogtied Dionesia Lasconia to fabricate her noninvolvement before leaving the scene.

On February 21, 2005, an Information was filed before the RTC charging Eddie Olazo, Miguel Corbis, Charito Fernandez, and others with the crime of Robbery with Homicide.
During the arraignment, Rommel Escobio pleaded guilty while Eddie Fernandez remained at large.
At trial, state witness Joseph Oronos provided critical testimony:

He detailed how he was hired on more than one occasion by the group; first, during the planning stage in July 2004, and later on the evening of August 8, 2004.
His account included overhearing discussions about “killing” to conceal the robbery, and identifying Charito’s participation.
He further testified that Charito paid for his motorcycle used in the getaway and threatened him to ensure silence.

Dionesia Lasconia pleaded guilty to a lesser offense (Homicide) on the condition that she would corroborate Joseph’s testimony.
The RTC, in its Decision dated June 14, 2011, convicted Charito Fernandez along with Rogelio Lasconia, Eddie Olazo, and Miguel Corbis, sentencing them accordingly.

On appeal, the Court of Appeals (CA) affirmed the RTC’s conviction of Charito Fernandez but acquitted Eddie Olazo and Miguel Corbis due to insufficient evidence of their participation.
Accused-appellant Charito Fernandez filed a Notice of Appeal, elevating the case to the Supreme Court.
Subsequent supplemental briefs and manifestations reaffirmed the parties’ earlier positions.
The central contention on appeal was whether the RTC mistakenly relied on the evidence regarding Charito’s participation in both the plan and the actual execution of the crime.

Whether the evidence was sufficient to prove, beyond reasonable doubt, that Charito Fernandez participated in the planning and execution of the robbery with homicide.
Whether the overt acts during the commission of the crime and the state witness’s testimony adequately established the necessary criminal conspiracy.

Whether Charito’s involvement in planning and his subsequent actions during and after the crime constitute conspiracy under Philippine law.
If mere participation in the planning stages, without evidence of actual physical involvement, is enough to convict him of a felony like Robbery with Homicide.

Whether the evidence demonstrated the aggravating circumstances of “evident premeditation” and “abuse of superior strength.”
How the presence of these aggravating circumstances should affect the imposition of penalties under Article 63 of the Revised Penal Code.