Case Summary (G.R. No. 212932)
Applicable Law and Charges
Balute was charged with Robbery with Homicide under Article 294(1) of the Revised Penal Code (RPC), as amended by Republic Act No. 7659, which penalizes robbery accompanied by homicide with reclusion perpetua to death. The prosecution charged that Balute, together with another unidentified individual, forcibly took a cellular phone from SPO1 Manaois and shot him, causing his death.
Facts Established
On the night of March 22, 2002, SPO1 Manaois was inside his owner-type jeepney in Tondo, Manila, accompanied by his wife Cristita and daughter Blesilda. While stopped in heavy traffic, two men—Balute and another—approached the vehicle. Balute pointed a gun at Manaois, cursed him, grabbed his Nokia 3210 phone from his pocket, and shot him in the left torso. Manaois attempted to draw his firearm but collapsed and later died despite medical intervention.
Defense and Alibi
Balute denied involvement, asserting an alibi that he was at his workplace, a pedicab welding shop operated by Leticia Nicol, from 8:00 a.m. to 10:00 p.m. Nicol supported this claim and implicated other individuals as responsible.
Regional Trial Court’s Decision
The RTC found Balute guilty beyond reasonable doubt of Robbery with Homicide with the aggravating circumstance of treachery. He was sentenced to reclusion perpetua without parole eligibility and ordered to pay P50,000 civil indemnity, P6,000 compensatory damages for the stolen phone, and P50,000 moral damages with six percent interest per annum from the information filing. The court favored the positive identification by the victim’s wife and daughter over Balute’s alibi.
Court of Appeals’ Ruling
The Court of Appeals affirmed Balute’s conviction but modified some aspects: (a) excluded treachery as aggravating circumstance since not alleged in the information; (b) increased civil indemnity to P75,000 following prevailing jurisprudence; (c) deleted compensatory damages for the phone’s value for lack of competent evidence, instead awarding actual damages of P140,413.53 for hospital and funeral expenses; and (d) imposed six percent interest on all damages from the decree’s finality.
Issue Before the Supreme Court
The sole issue was whether the Court of Appeals correctly upheld the conviction of Balute for Robbery with Homicide.
Supreme Court’s Analysis on Factual Findings
The Supreme Court reaffirmed the principle that factual findings of lower courts are given great weight and are only disturbed under compelling reasons. It found no basis to overturn the RTC and CA decisions since the prosecution satisfactorily proved the elements of Robbery with Homicide beyond reasonable doubt.
Elements of Robbery with Homicide
The Court cited People v. Ibañez, elaborating that to convict for Robbery with Homicide, the prosecution must prove: (1) unlawful taking of personal property belonging to another; (2) intent to gain; (3) use of violence or intimidation; and (4) commission of homicide by reason or on occasion of the robbery. The robbery must be the principal objective, and the killing incidental, with intent to rob preceding the taking of life. The homicide must relate to facilitating the robbery, escape, preserving possession of loot, preventing discovery, or eliminating witnesses.
Application of Law to Facts
The Court agreed that Balute pointed the gun at SPO1 Manaois, took his cellular phone, and fatally shot him. The eyewitness testimony of the victim’s wife and daughter was categorical, consistent, and untainted by ill motive, outweighing Balut
...continue readingCase Syllabus (G.R. No. 212932)
Case Background and Procedural History
- This case is an ordinary appeal filed by accused-appellant Arnel Balute y Villanueva (hereafter "Balute") assailing the February 3, 2014 Decision of the Court of Appeals (CA) in CA-G.R. CR-HC No. 05649.
- The CA affirmed the June 11, 2012 Decision of the Regional Trial Court of Manila, Branch 18 (RTC) in Criminal Case No. 03-211951.
- The RTC found Balute guilty beyond reasonable doubt of the special complex crime of Robbery with Homicide under Article 294(1) of the Revised Penal Code (RPC), as amended.
- The appeal to the Supreme Court arose from Balute’s conviction, with the core issue focused on the correctness of the CA’s affirmation of the RTC’s ruling.
Facts of the Case
- On March 22, 2002, in Manila, SPO1 Raymundo B. Manaois was driving his owner-type jeepney with his wife Cristita and daughter Blesilda along Road 10, Tondo.
- At a stoplight, two men, later identified as Balute and Leo Blaster, appeared on either side of the jeepney.
- Balute allegedly poked a gun at SPO1 Manaois and demanded compliance, exclaiming a putangina, ilabas mo! (a profane command to surrender).
- Balute forcibly grabbed SPO1 Manaois’s Nokia 3210 mobile phone from his chest pocket, valued at P6,000.
- Immediately after, Balute shot SPO1 Manaois in the left side of his torso.
- SPO1 Manaois attempted to draw his firearm and exit his jeepney but fell to the ground and was rushed to Mary Johnston Hospital.
- Despite surgical and medical intervention, SPO1 Manaois died from a mortal gunshot wound.
- Balute, in his defense, denied knowledge of the crime, claiming an alibi of working as a pedicab welder at Leticia Nicol’s shop from 8:00 AM to 10:00 PM on the day in question.
- Nicol corroborated Balute’s alibi, suggesting other suspects were liable.
- The prosecution presented eyewitness testimonies, including that of the wife and daughter of the victim, identifying Balute as the assailant.
Charges and Legal Definition Invoked
- Balute was charged with Robbery with Homicide under Article 294(1) of the RPC as amended by Republic Act No. 7659.
- The Information stated that the crime occurred through conspiracy, use of force and intimidation, unlawful taking of property (mobile phone), and the commission of homicide by shooting the victim which directly caused his death.
- The special complex crime requires that the homicide be committed by reason or on the occasion of the robbery.
RTC’s Findings and Ruling
- The RTC rendered a conviction finding Balute guilty beyond reasonable doubt of Robbery with Homic