G.R. No. 127759-60 - People vs. Feliciano

The accused, John Carlo Salga and Ruel "Tawing" Namalata, were charged with robbery with homicide.
The incident occurred on or about February 14, 2010, at Barangay Damilag, Manolo Fortich, Bukidnon, Philippines.
The alleged robbery was committed at the house of Josefina Zulita y Edralin, with part of the offense involving the robbery of cash (P34,000.00) and a Samsung E590 cellphone.
During the robbery, the accused allegedly attacked Catalina Arcega, the househelper, resulting in her mortal injuries and subsequent death.
The crime was charged as a violation of Article 294(1) of the Revised Penal Code.

The accused were initially arraigned and entered pleas of "not guilty."
Salga surrendered on July 11, 2011, and was subsequently placed in custody; his pre-trial was concluded on August 3, 2011.
Namalata was arrested earlier, on August 16, 2010, and detained, with pre-trial proceedings terminated on April 18, 2011.
Trial on the merits ensued with the prosecution presenting multiple witnesses, including Joan Camille Zulita, Constancio Hinlo, Jr., Dr. Broxil Macabinlar, and others.
The defense presented counter-testimonies from friends, relatives, and co-accused to establish alibis and contest the evidence.

Joan Camille Zulita testified that she saw three persons entering the house, including an armed man (identified later as John) who coerced her to open the vault.
She recounted her experience of hiding and later discovering that the valuables had been taken.
Constancio Hinlo, Jr., a civilian volunteer, testified about seeing a green motorcycle speeding away with John and Ruel (with another unidentified occupant).
Additional testimonies established the events surrounding the robbery and the fatality of Catalina Arcega, including medical evidence regarding the cause of death.

Appellant Salga claimed he was working at a fish pond in Luyong Baybayon, Misamis Oriental at the time of the robbery.
His alibi was corroborated by his uncle, Angelito Salga, and Cesar Pabillan.
Appellant Ruel Namalata, along with his friends Marcelo Abenaza, Celso Baol, Jr., and others, claimed he stayed home and engaged in leisure activities, such as watching a boxing bout and a drinking session.

The Regional Trial Court (RTC) convicted both Salga and Namalata for robbery with homicide based on the witness testimonies and circumstantial evidence, finding a conspiracy among the accused.
The RTC imposed reclusion perpetua on both and ordered them to pay various amounts as actual, moral, exemplary, temperate, and civil damages to the victims and their heirs.
The Court of Appeals (CA) affirmed the RTC’s decision, modifying the orders on payment of damages but upholding the conviction, particularly emphasizing the credibility of the prosecution’s witnesses and the circumstantial evidence pointing to the participation of both accused.

The CA maintained that the act of driving a green motorcycle by Ruel, alongside John, following the robbery was evidence of coordinated action.
Testimonies by Constancio Hinlo, Jr. and others were used to assert that the accused acted in concert; however, questions emerged as to whether mere presence or association was enough to establish a conspiratorial overt act.

Whether or not the elements of robbery with homicide, as a composite crime, were sufficiently proven beyond reasonable doubt.

Specifically, whether the intent to commit robbery, which preceded the homicide, was clearly established.

Whether the out-of-court identification of John Carlo Salga by witness Joan Camille Zulita met the constitutional standards of reliability and due process.

Consideration of the totality-of-the-circumstances test regarding witness opportunity, attention, prior description, certainty, timing, and suggestiveness.

Whether circumstantial evidence was adequate to establish the participation of Ruel Namalata in the crime, particularly his alleged role in the conspiracy.

Assessment of whether an overt act was committed by Ruel to indicate his involvement in a conspiracy to commit the crime.

Whether the findings on conspiracy, design, and coordination among the accused were legally and factually supported.

Determination if mere presence at the scene or association with the accused could be equated with an overt act in furtherance of a criminal plan.

The propriety of the damages awards granted by the lower courts and whether they conformed to existing jurisprudence such as People v. Jugueta.