G.R. No. 108919 - People vs. Pinlac y Baniqued

Several accused—including Edgar Cordero, Ernesto Pinlac, Jimmy Salazar, Elpidio Batac (alias “Domingo” or “Ace”), Domingo Batac (alias “Dennis”), Sales Sabadao (alias “Sonny”), Marlon Angco, Fred Batac, Ben Balocon (at large), and unidentified John Does—were charged with robbery with homicide committed against Gary Salvosa.
The Third Amended Information charged that on August 12, 1990, at the GP Shopping Arcade in Baguio City, the accused, acting in conspiracy, used violence, intimidation, and deadly weapons during a robbery which resulted in the stabbing death of the victim.
Certain accused, such as Edgar Cordero and Domingo Batac, entered pleas of guilty at arraignment; the remaining, except for the fugitive Balocon, pleaded not guilty.

Victim – Gary Salvosa, a 41-year-old businessman and owner of the GP Shopping Arcade that also served as his residence, was attacked after arriving in his pickup vehicle to the building in which he occasionally slept despite moving out due to building safety concerns following an earthquake.
The crime involved a meticulously planned sequence wherein the accused conspired beforehand, and on the day of the incident, they arrived at the building, locked the gate, and ambushed Salvosa.
Evidence indicated that the assailants used multiple weapons (dagger, firearms including a Glock pistol, Uzi machine pistol, shotgun, and Browning pistol) and inflicted a series of stab wounds, eventually causing the victim’s death from massive hemorrhage and hypovolemic shock.

Prior to the robbery, information and planning among the accused were gathered where roles were delineated. For example, Pinlac, a former Vice-Mayor, served as the organizer by providing his jeep and meeting place, while Cordero, a security guard on duty, executed the arrest of the victim under threat.
The victim’s personal belongings, such as a wallet containing cash, a Seiko wristwatch, and several high‑valued firearms and vehicles (including a Nissan pickup), were seized by the perpetrators.
The crime scene was left in disarray with evidence such as torn strips of cloth that tied the victim and other physical clues discovered by police, including the abandoned Nissan pickup used for the getaway.

The discovery of the crime was made the following day when Gary Salvosa’s body was found at the penthouse by his son and a janitor.
A detailed investigation ensued involving the City Police, the CIS, and the NBI. Witnesses – including state witness Marlon Angco – and forensic evidence played a crucial role in identifying and linking the accused to the commission of the crime.
A series of arrests followed based on testimonies and material evidence, including the seizure of the stolen firearms and the recovery of items such as the victim’s pickup and other effect from various hideouts and locations.

At trial, the accused were charged as principals or accomplices in the crime with corresponding degrees of participation.
Notable procedural issues arose regarding the discharge of Marlon Angco as a state witness. Using Section 9, Rule 119 of the Rules of Court, the trial court approved his discharge despite his involvement in part of the events, on the grounds that he did not appear to be the most guilty among the accused and his testimony was necessary for the prosecution.
The trial court rendered judgments, sentencing most of the accused to reclusion perpetua and, for Sales Sabadao, imprisonment ranging from 12 years to 20 years for his role as an accomplice. In addition, the accused were held civilly liable for various amounts computed for actual, consequential, moral, exemplary damages, and indemnification for loss of earning capacity, which were later subject to recalibration by the reviewing court.

Whether it was proper to discharge Marlon Angco as a state witness despite his involvement in the incident, particularly given his presence at the crime scene, and whether his testimony should be accorded full credibility.
Whether the requirements under Section 9, Rule 119 of the Rules of Court were satisfied in ordering such discharge, considering factors like necessity of his testimony and his comparative level of culpability.

Whether the elements of conspiracy were properly established by circumstantial evidence demonstrating a common criminal purpose among the accused.
The sufficiency and credibility of evidence against co-accused such as Pinlac and Sabadao in linking them to the planning and execution of the crime.
Whether the defense alibi raised by some accused was credible and supported by clear and convincing evidence.

The correctness of the trial court’s computation of the victim’s loss of earning capacity, particularly the method used and the subsequent award for consequential damages.
Whether certain expenses claimed in the computation of actual damages were rightly included under existing guidelines and jurisprudence concerning reimbursement for expenses related to the victim’s death.