G.R. No. 240662 - People vs. Rapiz y Correa

On September 21, 2001, at around 10:00 p.m. in Manila, the accused—Bobby Torres @ Roberto Torres y Nava—and his co-accused allegedly committed a robbery with homicide against Jaime M. Espino.
The crime occurred on C.M. Recto Avenue near Ylaya Street in Tondo, Manila, where the accused, armed with bladed weapons, blocked Espino’s path as he drove his car.

According to the Amended Information filed on January 28, 2004, the accused conspired with at least one unidentified malefactor and among themselves to commit the offense.
The accused are alleged to have forcibly grabbed Espino’s belt-bag, leading to a struggle during which a series of multiple stabbings were inflicted on Espino, ultimately causing his death.
After incapacitating Espino, his belt-bag, along with his wallet, necklace, watch, and rings, were taken by the accused.

The accused include Reynaldo Torres, Jay Torres, Ronnie Torres, and the appellant, Bobby Torres @ Roberto Torres y Nava.
Only Bobby Torres was arrested; the other siblings remained at-large at the time of trial.
The prosecution charged the accused with the special complex crime of robbery with homicide.

Espino was engaged in routine travel when his path was blocked by Ronnie.
Following Espino’s natural response—alighting from his car—a struggle ensued over his belt-bag, and subsequently, the accused attacked him with knives.

Dr. Romeo T. Salen’s medico-legal report confirmed that Espino died from multiple stab wounds on different parts of his body, indicating more than one assailant was involved.
Additional evidence included the testimony of Espino’s daughter regarding the value of the jewelry and other personal effects taken.

The appellant denied any participation in the robbery and homicide.
He testified that he was with his girlfriend, Merlita Hilario, at a friend's house in Villaruel, Tayuman, Manila, engaging in a drinking session until they later retired for the night.
Witnesses Merlita Hilario and Marilou Garcia, as well as Jorna Yabut-Torres (wife of one co-accused), corroborated alternative versions attempting to explain the sequence of events in a manner that differed from the prosecution’s narrative.

The Regional Trial Court (RTC) initially found Bobby Torres guilty of murder, basing the decision on evidence of abuse of superior strength.
Although the prosecution had charged him with robbery with homicide, the RTC deemed that the robbery element was not indubitably established, thus convicting him solely for murder.
On appeal, however, the Court of Appeals (CA) modified the RTC ruling by holding that the primary intention was to rob Espino with the homicide being committed incidentally, and convicted the appellant of robbery with homicide.

Whether the appellant’s challenge based on double jeopardy is valid given that he originally contested his conviction for murder while the CA modified the conviction to robbery with homicide.
The appellant contended that his acquittal on the robbery charge should remain final and that his subsequent conviction for robbery with homicide placed him twice in jeopardy.

Whether the evidence clearly shows that the primary criminal intention of the accused was to commit robbery, with the killing being merely incidental.
The determination of whether evincing actions at the crime scene (i.e. the blocking of the car and the struggle over the belt-bag) sufficiently prove robbery as the central intent.

Whether the testimony of eyewitnesses and the medico-legal report establishing multiple stab wounds amount to sufficient proof of the commission of the crime, despite admitted minor inconsistencies.
Consideration of whether the failure to present the actual weapons used materially affected the establishment of corpus delicti.

Whether the defense’s alibi, which placed the appellant at a friend’s house during the crime, is credible and meets the strict requirements pertaining to time and place.