G.R. No. 99355 - People vs. Salazar y Seroma

On March 10, 1989, in Quezon City, Metro-Manila, an incident occurred involving the alleged robbery with homicide of Crispin Gatmen, a security guard.
The accused—Domingo Salazar y Seroma (alias aInggoa) and Monchito Gotangugan y Sevilla (alias aMonchinga), together with an unidentified accomplice—were charged in an Information for robbery with homicide.
The charge was based on the allegation that the accused, while conspiring together, used violence and intimidation to rob the victim of his service firearm and, in the process, inflicted fatal stab wounds.

Pfc. Jose Antonio of the Quezon City Police.
Two key eyewitnesses, Vicente Miranda, Jr. and Pedro Soriano.
Expert testimony from Dr. Dario L. Gajardo of the PC/INP Crime Laboratory.
Additional input from Ben Felipe Dangza, Consultant/Manager of PUMA Security Agency.

Witnesses observed the accused approaching the security guard at Lindaas Supermarket.
Salazar was seen conversing with the guard, during which he produced a dagger and handed it to Gotangugan.
Gotangugan then used the dagger to stab the guard repeatedly, resulting in multiple fatal wounds.
After the stabbing, both Salazar and Gotangugan, along with their unidentified companion, appropriated the guard’s revolver.
Detailed forensic evidence recorded various stab wounds on the victim confirming the violent nature of the assault.

Domingo Salazar was at his residence in Quezon City during the early hours of March 10, 1989, sleeping with his wife and father-in-law.
Monchito Gotangugan claimed that he was in Lucena City on the day of the crime and later at his sister’s house.

Both appellants testified that they were forcibly taken by police on July 27, 1989, and denied any involvement in the killing at Lindaas Supermarket.
The defense alleged that the eyewitness testimonies contained inconsistencies and that some evidences were tainted by alleged illegal arrest procedures.

The trial court, acting as a special criminal court, dismissed the defense alibi as inherently weak.
It gave full credence to the consistent and corroborated testimonies of the prosecution’s eyewitnesses.
Based on the evaluation of the evidence, the trial court convicted both accused for the crime of robbery with homicide and imposed reclusión perpetua, along with other penalties, including indemnity for the loss suffered by the victim’s heirs.

The lower court erred in giving undue weight to the prosecution witnesses’ testimonies, alleging inconsistencies and contradictions.
The evidence was insufficient to prove the crime beyond reasonable doubt.
Evidence obtained after an alleged illegal arrest should have been excluded.
The defense’s alibi, which included their claim of being police informants, was improperly disregarded.

Whether the testimonies of the eyewitnesses, despite perceived inconsistencies, were sufficiently credible to establish the facts of the crime.
Whether the alleged material inconsistencies in the eyewitness accounts undermined their reliability.

Whether the killing of the security guard was committed as an incidental act during the commission of a robbery or whether the acts constituted two separate offenses—homicide and theft.
Whether the primary criminal intent (animus lucrandi) focused on the asportation of personal property, making the homicide merely an incidental occurrence.

Whether the sequence of events and forensic evidence conclusively linked the accused to the stabbing and subsequent asportation of property.
Whether the alleged illegal arrest and subsequent evidence gathering affected the admissibility or weight of the eyewitness testimonies.