Case Digest (G.R. No. 130656)
Facts:
People of the Philippines v. Armando Reanzares, G.R. No. 130656, June 28, 2000, Supreme Court En Banc, Bellosillo, J., writing for the Court.The accused is Armando Reanzares (also known as "Armando Rianzares"), convicted by the Regional Trial Court (RTC) of Tanauan, Batangas, Branch 6, on 26 May 1997 of Highway Robbery with Homicide under PD 532 and sentenced to death. The RTC also awarded several sums as indemnity, funeral and related expenses, actual damages, and reimbursement for a watch, and acquitted him of a separate carnapping charge under RA 6539.
On the night of 10 May 1994, spouses Gregorio and Lilia Tactacan were returning home by their passenger-type jeepney after closing their sari-sari store in Sto. Tomas, Batangas. Two unidentified men boarded as hitchhikers; after some 500 meters one drew a .38 revolver at Gregorio and the other threatened Lilia with a balisong. Two other persons, one later identified as the accused, were seen waiting at a distance; the assailants gagged, blindfolded and tied Gregorio, took his Seiko wristwatch, and forced the accused to drive. Gregorio later heard a commotion, Lilia cry out and then fall silent; he escaped, sought help, and found his wife bleeding and later pronounced dead on arrival at the hospital. The medical examiner testified to multiple stab wounds caused by a sharp pointed object and opined that several persons must have inflicted the wounds.
The prosecution filed two Informations: one for violation of PD 532 (Anti-Piracy and Anti-Highway Robbery Law of 1974) charging robbery with homicide during a highway robbery, and another for carnapping under RA 6539. Only Reanzares was arrested; three co-accused remained John Does at large.
At trial the prosecution relied principally on the positive identification of the accused by Gregorio Tactacan and medical evidence of homicide. The accused presented an alibi: he testified that he was in Bicol for his daughter's baptism, supported by testimony from his father and brother that he left for the trip and was seen off at the bus stop. The RTC found the prosecution credible, disbelieved the alibi, convicted the accused of Highway Robbery with Homicide under PD 532 and imposed death, while acquitting him of carnapping for lack of evidence.
On automatic review to the Supreme Court (as required for death sentences), the accused contended that his guilt was not proven beyond reasonable doubt, that the identifying witness was unreliable, that his alibi was credible, and that the RTC erred in convic...(Subscriber-Only)
Issues:
- Was the guilt of accused Armando Reanzares proved beyond reasonable doubt?
- Was the conviction for Highway Robbery under PD 532 proper, or should the accused have been convicted of Robbery with Homicide under Article 294 of the Revised Penal Code as amended by RA 7659?
- Were the damages awarded by the trial court proper i...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
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