Case Summary (G.R. No. 252276)
Charges and Legal Basis
Jerrico was charged under Article 294 of the Revised Penal Code (RPC), as amended by Republic Act (RA) No. 7659, for robbery with homicide, involving the taking of money and a firearm from Florante Garcia, who was fatally shot during the commission of the robbery. RA No. 9346, which prohibits the death penalty in the Philippines, is also applicable in this case in relation to penalty imposition.
Facts Established by Prosecution
Multiple witnesses testified to the circumstances surrounding the crime, including Amalia Valentin, who saw a man in a white cap, red and blue jacket, and blue handkerchief shoot the victim and rob his belongings. Angel Bonbon, a carinderia employee, corroborated this description and identified the accused through his booking sheet and in court after recovering the suspect’s bloodstained clothing and personal effects. Police officers found the crime scene, recovered the motorcycle used, and corroborated witness statements. Marlon Geronimo testified that Jerrico borrowed his motorcycle on the date of the incident and later apologized for the involvement, indicating consciousness of guilt or awareness of the act.
Defense Testimony and Arguments
Jerrico denied involvement, claiming an alibi suggesting he was elsewhere during the time of the incident. He testified that he borrowed a motorcycle to buy spare parts and later lost it at the fish port. Other defense witnesses provided testimony to support his alibi and presence elsewhere. However, the defense’s denial and alibi lacked clear and convincing evidence to dispel the prosecution’s circumstantial evidence.
Trial Court’s Findings and Ruling
The RTC found Jerrico guilty beyond reasonable doubt based on a solid chain of circumstantial evidence that linked him to the robbery with homicide. The Court emphasized that circumstantial evidence, when forming an unbroken chain leading to a single conclusion excluding all others, is sufficient for conviction. The RTC sentenced Jerrico to reclusion perpetua and awarded civil indemnity, moral damages, and exemplary damages of PHP 100,000.00 each to the victim’s heirs.
Court of Appeals’ Affirmation
The Court of Appeals affirmed the RTC’s conviction and ruling in its June 20, 2019 decision, dismissing the appellant’s claim of mistaken identity and failure of proof. The CA upheld that the prosecution established an unbroken chain of circumstances pointing solely to Jerrico as the perpetrator, thereby sustaining the conviction based on circumstantial evidence.
Supreme Court’s Analysis on Circumstantial Evidence
The Supreme Court reiterated the rule that circumstantial evidence is admissible and sufficient to convict so long as it meets the criteria of fifteen tested circumstances producing a conviction beyond reasonable doubt. The Court applied this doctrine, emphasizing that the evidence consistently identified Jerrico as the assailant and that his defenses of denial and alibi were self-serving and not supported by strong evidence.
Elements and Nature of Robbery with Homicide
The Court expounded on the elements of robbery with homicide under Article 294 of the RPC: (1) taking of personal property with violence or intimidation; (2) the property belongs to another; (3) intent to gain; and (4) homicide was committed on occasion or by reason of the robbery. The Court explained that the homicide is incidental to the robbery and need not be premeditated as a separate crime.
Treachery as a Generic Aggravating Circumstance
Although treachery is not an element of robbery with homicide, the Court held that the killing of Florante was committed treacherously. Treachery, defined by the stealthy and unexpected nature of the attack that precludes the victim’s defense or retaliation, serves as a generic aggravating circumstance that increases the penalty. The Court cited precedents such as People v. Escote, Jr. and People v. Baron, confirming treachery’s role as a generic aggravating circumstance in robbery with homicide.
Penalty Imposition and Effect of RA No. 9346
The Court clarified that the presence of treachery would ordinarily elevate the penalty to death. However, due to RA No. 9346 prohibiting the death penalty, Jerrico m
...continue readingCase Syllabus (G.R. No. 252276)
Background and Charges
- Jerrico Juada y Navarro (hereafter, "Jerrico") was charged with robbery with homicide under Article 294 of the Revised Penal Code, as amended by Republic Act No. 7659.
- The incident occurred on December 18, 2011, in Bocaue, Bulacan, where Jerrico allegedly willfully and unlawfully took cash amounting to P110,000.00 and a Colt MK IV .45 pistol from Florante Garcia y Celestino ("Florante"), with intent to gain, by means of violence and intimidation.
- During the robbery, Jerrico reportedly treacherously shot Florante, causing instantaneous death.
- Jerrico pleaded not guilty at trial.
Evidence Presented at Trial
- Prosecution witnesses included traffic enforcer Amalia Valentin, PO2 Carlito Bucco, Jr., Angel Bonbon (wait staff), PO3 Richard Higoy, Marlon Geronimo, and Jonathan Garcia.
- Amalia identified a man wearing a white cap, red and blue jacket, and blue handkerchief covering his face, as the assailant who shot Florante at close range and took his belongings.
- Angel saw the same man soon after in a carinderia, noticed blood stains on a table and the man’s abandoned clothes, identified later as Jerrico through his booking record.
- Police officers corroborated the sequence of events leading to recovery of the suspect’s belongings and motorcycle used in the crime.
- Marlon testified that he lent his motorcycle to Jerrico on the day of the incident, and that Jerrico later apologized and expressed concern about the case status.
- Jonathan described the crime scene and the police’s notification about Jerrico’s arrest.
- The defense presented Jerrico and alibi witnesses, who denied his involvement and asserted he was elsewhere during the incident.
- Despite the defense’s claims, the trial court found an unbroken chain of circumstantial evidence pointing to Jerrico as the perpetrator.
Trial Court’s Decision and Sentence
- The Regional Trial Court (RTC) convicted Jerrico of robbery with homicide, emphasizing the sufficiency of circumstantial evidence.
- The Court noted the crime’s complex nature, with homicide incidental to robbery.
- Jerrico was sentenced to reclusion perpetua, abiding by RA No. 9346 which abolished the death penalty and prescribes life imprisonment without parole in lieu.
- Civil liabilities were imposed: P100,000.00 each for civil indemnity, moral damages, and exemplary damages in favor of the victim’s heirs.
Appeal and Court of Appeals Ruling
- Jerrico appealed to the Court of Appeals (CA), contesting his identification and claiming the trial court ignored his alibi.
- The CA, in its decision dated June 20, 2019, affirmed the RTC ruling, upholding the conviction and penalties.
- The CA respected the trial court’s assessment of witness credibility and consistency of circumstantial evidence.
- The CA dismissed Jerrico’s appeal for lack of merit.
Supreme Court’s Review on Circumstantial Evidence
- The Supreme Court (SC) reiterated that conviction by c