G.R. No. 221427 - People vs. Labagala

Case Summary (G.R. No. 221427)

Factual Background

On June 12, 2002, at about 7:30 p.m., the victim was at his residence under a mango tree when four men entered the compound. An eyewitness, Jun Alberto, testified that he identified two of those men in open court as the accused-appellants. Jun narrated that Alvin J. Labagala poked a gun at the victim, whipped him with the gun, and seized his jewelry consisting of two rings, a necklace, and a wristwatch. Jun further testified that the assailants dragged the victim into the house, that he heard commotion and moaning, and that the assailants immediately fled the scene; when Jun entered the house he found the victim already dead.

Criminal Information and Plea

An Amended Information dated December 23, 2002 charged appellants and three others with robbery with homicide, alleging that the accused, armed with a deadly weapon and with intent to gain, forcibly took the victim’s jewelry and cash and that, on the occasion of the robbery, the accused, with intent to kill, attacked and wounded the victim causing his death. Upon arraignment appellants pleaded not guilty and the case proceeded to trial.

Defense Contentions

The defense presented denial and alibi. Romeo Labagala testified that he resided in Homestead II, Talavera, Nueva Ecija, and had been harvesting palay in Barangay Dicos and stayed there for almost a month, making travel to the scene implausible. Alvin Labagala testified that he was in Tanza, Navotas, selling vegetables with acquaintances during the relevant period and that travel to the victim’s residence would not comport with his account. The defense sought to cast reasonable doubt on the identification and presence of the accused at the scene.

Trial Court Proceedings and Ruling

The Regional Trial Court, Branch 27, Cabanatuan City, after trial and evaluation of evidence, convicted appellants of robbery with homicide under Article 293 in relation to Article 294, paragraph 1 of the Revised Penal Code, and sentenced them to reclusion perpetua. The RTC acquitted co-accused Salve for failure of the prosecution to prove guilt beyond reasonable doubt, archived the cases against two other co-accused at large, and issued alias warrants. The RTC found the testimony of Jun to be clear and credible, concluded that conspiracy and mutual aid among the assailants were established, and rejected the defenses of denial and alibi.

Court of Appeals Decision

On appeal the Court of Appeals affirmed the RTC Decision in toto. The CA found that the prosecution proved that the appellants’ overriding intention was to commit robbery and that the homicide was incidental to and on the occasion of the robbery, thereby satisfying the elements of robbery with homicide. The CA sustained Jun’s testimony as positive and credible and agreed that the circumstances demonstrated conspiracy among the appellants and the co-accused at large.

Issues Presented on Appeal to the Supreme Court

Appellants advanced two principal issues: first, whether the prosecution proved all the elements of robbery with homicide, particularly given that Jun’s testimony was uncorroborated; and second, whether appellants and their co-accused at large acted in conspiracy in committing the crime.

Governing Law and Required Elements

The Court set forth the controlling law under Article 294, paragraph 1 of the Revised Penal Code, and identified the elements the prosecution must establish to convict for robbery with homicide: (a) the taking of personal property with the use of violence or intimidation against the person; (b) that the property belonged to another; (c) that the taking was characterized by intent to gain; and (d) that on the occasion of or by reason of the robbery the crime of homicide was committed. The Court reiterated the settled rule that the original criminal design must be robbery and that the killing must be incidental thereto.

Credibility of the Sole Eyewitness and Sufficiency of Evidence

The Supreme Court held that the prosecution proved the elements of the offense through the testimony of Jun, an eyewitness who identified the appellants and narrated the sequence of events leading to the victim’s death. The Court applied the doctrine that the testimony of a single witness, if positive and credible, suffices to sustain conviction and accorded great respect to the trial court’s appraisal of witness credibility, citing the principle that appellate courts will not disturb factual findings unless clearly arbitrary or unsupported by the records.

Conspiracy and Principal Liability

The Court affirmed the findings that appellants and their co-accused acted in conspiracy. Relying on People v. De Jesus, the Court explained that all who participated as principals in the robbery are liable as principals in robbe

Case Syllabus (G.R. No. 221427)

Parties and Procedural Posture

People of the Philippines was the plaintiff-appellee and Alvin J. Labagala and Romeo Labagala were the accused-appellants in the criminal prosecution for robbery with homicide.
The case originated in the Regional Trial Court, Branch 27, Cabanatuan City, as Criminal Case No. 12694, where the accused were tried and convicted.
The accused appealed the RTC conviction to the Court of Appeals in CA-G.R. CR-HC No. 06040, which affirmed the conviction in a Decision dated June 27, 2014.
The accused then filed the present appeal to the Supreme Court which rendered the decision under review.

Key Facts

On June 12, 2002, at around 7:30 p.m., the victim, Mario P. Legaspi, Sr., was at his residence when four men entered his compound and confronted him.
An eyewitness, Jun Alberto, testified in open court that he identified two of the intruders as the appellants and that Alvin J. Labagala poked a gun at and whipped the victim with the gun.
Jun Alberto testified that the assailants, while holding the victim, took two rings, a necklace, and a wristwatch from the victim and that the victim was subsequently dragged inside the house and later found dead.
Co-accused Salve A. Pascual was later acquitted by the RTC for failure of the prosecution to prove guilt, while co-accused Pablito Palens a.k.a. "Jun" and Michael Doe remained at large with alias warrants issued.

Defense Contentions

The accused offered defenses of denial and alibi, asserting that Romeo Labagala was working and staying in Talavera, Nueva Ecija in the weeks surrounding June 12, 2002.
The accused asserted that Alvin J. Labagala was in Tanza, Navotas assisting friends in selling vegetables during the period of the incident and thus could not have been present at the scene.
The accused contended that the prosecution relied on uncorroborated testimony of a single witness and therefore failed to prove the elements of robbery with homicide beyond reasonable doubt.

Trial Court Findings

The RTC found the prosecution proved conspiracy among the accused and their co-accused in committing the robbery that resulted in the victim's death.
The RTC credited the positive and detailed testimony of eyewitness Jun Alberto and rejected the defenses of denial and alibi as not establishing reasonable doubt.
The RTC convicted Alvin J. Labagala and Romeo Labagala of robbery with homicide under Article 293 in relation to Article 294, par. 1, of the Revised Penal Code and imposed the penalty of reclusion perpetua.
The RTC ordered the accused to return the stolen jewelry