Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Leo Quemeggen and Janito de Luna as the accused-appellants. The events transpired on October 31, 1996, around 11:00 PM, in Navotas, Metro Manila. Noel Tabernilla, the driver of a passenger jeep, was held up by four individuals, including the appellants, who threatened him with a balisong and robbed the passengers of their valuables. After the robbery, the perpetrators fled the scene, and Tabernilla, along with several passengers, reported the incident to the nearest police detachment. The police, upon returning to the scene, encountered the robbers on a pedicab. Socrates Kagalingan, a passenger, recognized the suspects, leading to the arrest of three individuals, including de Luna, while Quemeggen managed to escape. During the arrest, the suspects attacked Police Officer Emelito Suing, who was shot in the head by one of the robbers, resulting in his death shortly after. An autopsy conducted by D...

Facts:

Incident Overview

• On October 31, 1996, at around 11:00 PM, Noel Tabernilla was driving his passenger jeep in Navotas, Metro Manila.
• Four passengers announced a hold-up. One robber poked a balisong at Tabernilla's neck, while the others divested passengers of their valuables.
• The robbers alighted at "Puting Bato," and Tabernilla, along with six or seven passengers, reported the incident to the police.

Arrest and Escalation

• Police officers accompanied the victims to the crime scene and encountered the robbers riding a pedicab.
• Socrates Kagalingan, a victim, recognized one robber still wearing his stolen belt bag.
• Three suspects, including Janito de Luna, were arrested, but Leo Quemeggen escaped.
• While in custody, the suspects attacked police officer Emelito Suing. De Luna held Suing, while another suspect shot him in the head, leading to his death.

Autopsy and Charges

• Dr. Rosalyn Cosidon conducted an autopsy on Suing, concluding that the cause of death was a gunshot wound to the head.
• Quemeggen and de Luna were charged with Robbery with Homicide under Article 294 of the Revised Penal Code.

Trial Proceedings

• During the trial, Tabernilla and Kagalingan testified for the prosecution. Dr. Cosidon's testimony was dispensed with due to the appellants' admission of her findings.
• The appellants interposed the defense of alibi, claiming they were elsewhere during the incident.

RTC Decision

• The RTC convicted both appellants of Robbery with Homicide, sentencing them to reclusion perpetua and ordering them to pay indemnities.

CA Decision

• The CA modified the RTC's decision, convicting Quemeggen of Robbery and de Luna of separate crimes of Robbery and Homicide.
• The CA found that Suing's death was not directly connected to the robbery, thus negating the special complex crime of Robbery with Homicide.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Credibility of Witnesses: The trial court's assessment of witness credibility is binding unless tainted with arbitrariness. The prosecution witnesses' testimonies were credible and sufficient to establish the appellants' guilt.
2. Elements of Robbery with Homicide: For Robbery with Homicide, the prosecution must prove:
   • Taking of personal property with violence or intimidation.
   • The property belongs to another.
   • The taking is with intent to gain.
   • Homicide is committed by reason or on the occasion of the robbery.
   • In this case, the homicide was not directly connected to the robbery, as Suing was killed after the robbery was consummated.
3. Separate Crimes: The CA correctly ruled that the appellants committed separate crimes of Robbery and Homicide, as the killing was not integral to the robbery.
4. Civil Indemnity: Civil indemnity for the victim's death is automatically imposed without need for further proof.
5. Release of Quemeggen: Quemeggen had already served more than the maximum penalty for Robbery and was ordered to be released.