Case Summary (G.R. No. 148730)
Incident Overview
On the morning of July 13, 1999, a CFFTI passenger bus, after completing its usual route, picked up additional passengers at EDSA-Guadalupe. Among the new passengers were the accused-appellants and a plainclothes police officer, SPO1 Ebona. The robbery began when Salboro brandished a firearm and announced a hold-up, followed by the assailants demanding money and valuables from the bus driver and conductor, as well as other passengers. During the chaos, SPO1 Ebona was shot by the robbers.
Aftermath and Arrest
The bus driver, Terry Edma, managed to escape the situation and reported the incident to local authorities. Following the robbery, detectives from the Criminal Investigation and Detection Group (CIDG) began the process of identifying the suspects. Edma and the conductor, Antonio Dormitorio, later identified Dela Cruz, Salboro, and San Pedro from police photographs. Additional efforts led to the arrest of Dela Cruz and Gener on July 15, and Salboro and San Pedro on July 16, 1999.
Defense and Testimonies
During the trial, accused-appellants raised a defense of denial and alibi, claiming they did not know each other and were not involved in the crime. Each presented individual alibis which placed them away from the scene at the time of the robbery. However, the trial court found the testimonies of prosecution witnesses, Edma and Dormitorio, credible. The court emphasized the importance of firsthand accounts and the position of the witnesses during the incident, ultimately rejecting the defense’s claims.
Court’s Conclusion on Credibility
The court reiterated that the trial judge is best positioned to evaluate witness credibility, having observed their demeanor and account delivery directly. It upheld the trial court's findings and noted that the positive identification by Edma and Dormitorio, both victims of the crime, was decisive. The testimonies were consistent and corroborated each other regarding the events of the robbery and shooting.
Evidence of Robbery with Homicide
The prosecution successfully established the elements necessary for a conviction of robbery with homicide: the taking of property through violence or intimidation, the property belonging to another, intent to gain, and the commission of homicide occurring during the robbery. The court asserted that all participants in the robbery were culpable for the homicide, regardless of whether they directly inflicted the fatal wound, unless they attempted to prevent the crime.
Sentencing and Penalties
The original decision by the trial court imposed the death penalty on the accused-appellants, interpreting the crime as worthy of such severity due to the loss of life involved. However, under the 2000 Revised Rules on Criminal Procedure, the Supreme Court
...continue readingCase Syllabus (G.R. No. 148730)
Case Overview
- The case involves an automatic review of the decision by the trial court that convicted accused-appellants Jose Dela Cruz y Dacillo, James Salboro y Jorolan, Edwin "Butch" Gener y Catean, and Arnel San Pedro y Tacome of robbery with homicide.
- The trial court imposed the supreme penalty of death on the accused-appellants.
- The incident occurred on July 13, 1999, during a bus ride in Quezon City.
Incident Details
- Time and Place: The robbery occurred at approximately 1:15 AM on July 13, 1999, involving a passenger bus of the Chinese-Filipino Friendship Transport, Inc. (CFFTI).
- Bus Details: The bus was driven by Terry Edma with conductor Antonio Dormitorio, returning to their garage after completing their route.
- Robbers: A group of seven individuals, including the accused-appellants, boarded the bus while it was en route to Fairview, Quezon City.
- Holdup Announcement: James Salboro brandished a .38 caliber revolver, announcing the holdup, while Arnel San Pedro commanded the conductor to surrender the fare collections.
Robbery Dynamics
- Actions of Accused-Appellants:
- Jose Dela Cruz threatened the bus driver while taking cash.
- The accused-appellants proceeded to rob other passengers of their money and valuables.
- SPO1 Joven Avida Ebona: An off-duty police officer who boarded the bus was killed during the robbery when he confronted the robbers.
- Witness Accounts: Both Edma and Dormitorio were able to observe the events closely, leading to the identification of the accus