Title
People vs. Empacis
Case
G.R. No. 95756
Decision Date
May 14, 1993
Five men conspired to rob and kill Fidel Saromines in his home, stabbing him fatally and stealing P12,000. Crisologo Empacis was convicted of robbery with homicide, with aggravating circumstances upheld.
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Case Summary (G.R. No. 95756)

Credibility of Witnesses

  • The Court found no significant errors in the Trial Court's judgment that would warrant a reversal or modification.
  • The testimonies of the victim's widow and son regarding the identity of the attackers, Romualdo Langomez and Crisologo Empacis, were deemed credible.
  • Crisologo's own testimony contradicted his claims of innocence, as he attempted to portray himself as a protector of the victim.
  • The Court noted that Crisologo's credibility was undermined by his false statements to the physician treating his injuries.
  • There was no plausible motive for the widow and son to fabricate their testimonies against Crisologo.

Minor Discrepancies in Testimony

  • A minor discrepancy in the victim's son Peter's testimony regarding the number of stab wounds inflicted was not sufficient to undermine his credibility.
  • The Court recognized that such discrepancies are common in unrehearsed witness accounts and do not detract from the overall reliability of the testimony.
  • The Trial Court's assessment of the credibility of the prosecution witnesses was upheld.

Factual Findings of the Trial Court

  • The Court reaffirmed the principle that factual findings of the Trial Court are given great respect on appeal.
  • The Court found no compelling evidence that material facts were overlooked or ignored that would lead to a different verdict.

Proof of Conspiracy

  • The evidence presented sufficiently established the existence of a conspiracy between Langomez and Crisologo.
  • Their actions, including pretending to be customers and coordinating the robbery, demonstrated a common objective.
  • The attackers worked together to subdue the victim and steal his money, indicating a premeditated plan.

Aggravating Circumstances: Craft or Fraud

  • The Court found that the aggravating circumstance of craft or fraud was applicable to Crisologo.
  • The accused pretended to be customers to gain entry into the victim's store, which facilitated the crime.
  • Previous cases were cited where similar deceptive tactics were recognized as aggravating circumstances.

Aggravating Circumstances: Nighttime

  • Nighttime was deemed an aggravating circumstance as it was deliberately sought to facilitate the crime.
  • The late hour reduced the likelihood of witnesses or assistance for the victim, aiding the commission of the robbery.

Aggravating Circumstances: Superior Strength

  • The Court clarified that the presence of superior strength requires evidence of excessive force used by the attackers.
  • Crisologo's participation in stabbing the victim demonstrated the use of combined strength to overpower an unarmed individual.

Civil Indemnity for Death

  • The Trial Court initially o...continue reading

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