G.R. No. 115192 - People vs. Salas

The incident stemmed from events dated March 6, 1992, when Virginia S. Talens, a 60‑year‑old woman, was fatally stabbed.
An Information was filed on October 14, 1992, charging Elmer Salas y David with Robbery with Homicide, alleging that in the early hours of March 6, 1992, the accused wilfully, unlawfully, and feloniously used a bladed weapon to stab the victim and, afterwards, absconded with a sum of money (approximately P2,000.00) and a piece of gold earring valued at P750.00.

On the evening of March 5, 1992, Virginia Talens attended a wake and engaged in gambling, carrying a purse containing cash believed to be worth P2,000.00.
Around 3:00 a.m. on March 6, 1992, Virginia Talens was last seen alive while in the company of four persons: Virginia herself, the accused, and Orlando and Richard Pangan.
Testimonies indicated that the accused was seen with the victim as they were going home from the wake in Barangay San Nicolas, Mexico, Pampanga.

Orlando Pangan testified that he, along with Richard Pangan, Virginia, and the accused, had been together during the incident, noting that he heard a loud shout after entering his house.
Other witnesses, such as Serafia Gutierrez and Resultay, provided corroborative details about the timeline and the victim’s actions (e.g., gambling at the wake, and the disappearance of her purse).

Autopsy findings by Dr. (Dominic) Aguda revealed a fatal stab wound on the victim’s neck, hematomas on her head and chest, and an abrasion on her chin.
Police investigators recovered a safety pin (used by the victim to fasten her missing purse), her wristwatch, an earring, a ring, and an envelope containing P135.00.
Bloodstains were detected on both the front door of the accused’s house and later on his clothing and yellow slippers after the incident.

Salas was seen with the victim on the early morning of March 6, 1992, but shortly afterwards abandoned his residence in his native Barrio San Nicolas.
He left his job as a painter in Sta. Ana, Pampanga on the same day, with his departure and subsequent absence being interpreted as indicative of flight.
Despite family members being notified and advised to surrender him, he eluded capture until September 22, 1992, when he was apprehended in Mexico, Pampanga after being recognized under the alias "Rommel Salas" following an unrelated vehicular accident.

The accused was arraigned on November 9, 1992, where he pleaded “Not Guilty” with the assistance of counsel.
During trial, the prosecution relied on the circumstantial evidence including eyewitness accounts, forensic evidence, and inconsistencies in the defense testimonies.
The trial court rendered a decision on March 14, 1994, convicting Salas of Robbery with Homicide and sentencing him to reclusion perpetua.
Additional orders included the reimbursement of P2,000.00 and indemnification of P50,000.00 to the heirs of the victim.

The accused denied ever being the last person with the victim, pointing fingers instead at Orlando and Richard Pangan.
He challenged the chain of circumstantial evidence, questioning the reliability of the evidence of robbery and the absence of recovered stolen items.
The accused argued that his movements, including leaving for a new job and the use of the alias “Rommel Salas,” were misinterpreted and should be considered as a voluntary surrender rather than flight.
He contended that minor variances in the testimonies of the defense witnesses should not have been disregarded by the trial court.

Whether the chain of circumstantial evidence presented by the state was consistent and complete enough to support a conviction for Robbery with Homicide.
Whether the established facts, though indirect, conclusively pointed to the guilt of the accused beyond reasonable doubt.

Whether the elements established in the case warranted a conviction for Robbery with Homicide, as opposed to simple homicide.
Whether the evidentiary gaps regarding the purported act of robbery (such as the lack of direct eyewitness testimony or recovery of the stolen items) detracted from the sufficiency of proof.

Whether the trial court erred in giving greater weight to the testimonies of the prosecution witnesses over the inconsistencies and minor variances in the defense witnesses’ accounts.
Whether the testimony from witnesses, including those related to the movements of the accused, sufficiently disproved his version of events.

Whether the accused’s flight immediately after the incident, and his eventual apprehension under an alias, served as sufficient indicia of guilt.
Whether the court properly assessed the significance of his claim of voluntary surrender, given that his delay in surrendering and use of an alias could equally indicate evasion.

Whether the accused’s arguments pointing towards the involvement of alternative suspects (namely, the Pangan duo) had a substantive basis in the evidence.
Whether the notion that the accused’s alternative explanations (such as leaving for a new job) were plausible enough to create reasonable doubt.