Case Summary (G.R. No. 185209)
Factual Background
On July 19, 1995, an Information was filed against the appellant and his co-accused, charging them with robbery with homicide for the death of Juanito Berallo. The charge detailed the premeditated and treacherous assault resulting in multiple stab wounds which ultimately caused Berallo’s death. The initial plea of the appellant was "not guilty."
Prosecution's Case
Witness testimonies outlined the events leading to the crime, including the appellant’s interactions with Berallo before the crime. The prosecution established that the appellant, along with his co-accused, conspired to rob the victim, culminating in the assault that resulted in his death. Evidence such as witness accounts, a police investigation revealing Berallo’s body, and a post-mortem examination indicating multiple stabs further supported the robbery and homicide charges.
Defendant's Argument
The appellant maintained that he had no role in the crime, claiming he was coerced by armed passengers in the tricycle. His defense indicated that he was not involved in the murder, but rather a victim of circumstance.
Rulings of the Regional Trial Court
On February 12, 2002, the Regional Trial Court ruled the appellant guilty beyond reasonable doubt of robbery with homicide, imposing the penalty of death and awarding damages to the victim’s heirs. The court established the presence of treachery as an aggravating circumstance in the crime.
Court of Appeals and Final Review
The Court of Appeals affirmed the trial court's decision but modified the penalty to reclusion perpetua and adjusted the damages awarded. The appellant sought a final review, contesting the trial court's findings on various grounds including the alleged absence of intent to kill and asserting that he acted under duress.
Legal Principles and Findings
The Supreme Court upheld the conviction, emphasizing that robbery with homicide features both robbery and homicide occurring either by reason or on occasion of the robbery. The Court pointed out that for conspiracy to exist, there need not be direct evidence but can be inferred from circumstantial evidence. The circumstantial evidence presented was significant enough to establish the appellant’s involvement beyond reasonable doubt.
Circumstantial Evidence Supporting Conviction
The Supreme Court reviewed numerous pieces of circumstantial evidence that substantiated the involvement of the appellant and his co-accused, concluding that they acted in concert with a unified purpose to kill and rob the victim. The evidence demonstrated a collaborative effort among the accused from the initial approach of Berallo to the concealment of the stolen property.
Consideration o
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Factual Antecedents
- On July 19, 1995, an Information was filed against Rene Baron y Tangarocan (appellant), Rey Villatima, and alias "Dedong" Bargo, for the special complex crime of robbery with homicide.
- The crime occurred on June 28, 1995, at approximately 9:00 PM in Hda. Sta. Ana, Brgy. Burgos, Cadiz City, where Juanito Berallo was assaulted and stabbed to death.
- The Information specified the items stolen during the incident, including a tricycle sidecar valued at P16,000.00, a Kawasaki motorcycle worth P103,536.00, and personal items totaling P5,050.00.
Prosecution’s Version
- Ernesto Joquino, Jr., a tricycle driver, witnessed the appellant approach Berallo, asking for a ride to Hacienda Caridad.
- Witness Pacita Caratao corroborated Joquino's account, noting the appellant's presence with Berallo before the incident.
- The next day, Berallo's body was found with 15 stab wounds, confirming the cause of death as severe hemorrhage from multiple stab wounds.
- The appellant admitted to taking Berallo's motorcycle and hiding it at the house of Villatima's aunt, Natividad Camparicio, who recognized the motorcycle.
Defense's Version
- The appellant denied involvement, claiming he was a victim of a hold-up by two armed passengers who forced him to comply.
- He alleged he was threatened at gunpoint, tied up, and later accompanied the passengers against his will.
- He maintained that he had no prior knowledge or participation in the robbery or murder of Berallo.
Ruling of the Regional Trial Court
- On February 12, 2002, the RTC found the appellant guilty beyond reasonable doubt