Case Summary (G.R. No. 221427)
Charges and Antecedent Facts
The appellants, together with co-accused Pablito Palens, Salve A. Pascual, and Michael Doe, were charged under an Amended Information that accused them of robbing Legaspi of valuable items valued at approximately P200,000. The charges included the use of deadly weapons and resulted in serious physical injuries that led to Legaspi's death. The prosecution established that the accused acted with conspiracy during the commission of the crime.
Prosecutor's Evidence
The prosecution's case relied heavily on the testimony of Jun Alberto, a witness who described the events leading up to and during the robbery. Alberto recounted that while he was dining with the victim, the appellants entered the yard and attacked Legaspi. He identified Alvin labagala as the individual who physically assaulted the victim with a gun while his accomplices restrained him. The witness heard clearly defined sounds of struggle and discovered the victim's lifeless body shortly thereafter.
Defense Strategy
In contrast, the defense presented denials and alibis for both appellants. Romeo Labagala claimed he was working in Nueva Ecija at the time of the incident, while Alvin Labagala stated he was in Tanza, Navotas, selling vegetables. They argued that their alibis should absolve them of involvement in the crime, asserting that they could not have participated physically or directly.
Ruling of the Regional Trial Court
The RTC, in its November 15, 2012 Decision, found the appellants guilty of robbery with homicide under the Revised Penal Code. It ruled that the prosecution established a conspiracy among the accused and found Jun Alberto’s eyewitness testimony credible. The court dismissed the defense of alibi and denial as insufficient against the strong evidence provided by the witness, leading to a sentence of reclusion perpetua for the appellants. Additionally, damages were awarded to the victim's heirs.
Court of Appeals Decision
The CA affirmed the RTC decision in its June 27, 2014 ruling, concluding that the prosecution had adequately established the elements of robbery with homicide. The appellate court emphasized the strength of Alberto's testimony, asserting that a single credible witness could suffice to support a conviction in criminal cases.
Issues on Appeal
The appellants raised two principal issues: whether the prosecution had sufficiently proven the elements of robbery with homicide given that Alberto's testimony was uncorroborated, and whether they had acted in conspiracy during the commission of the crime.
Court's Ruling on Appeal
The Supreme Court dismissed the appeal, reinforcing the notion that the prosecution proved all necessary elements for robbery with homicide, specifically highlighting the intrinsic connection between robbery and homicide as the latter was deemed incidental to the former. The court noted that the testimony of a single witness could indeed support a conviction when credible. Furthermore, the court ruled that since both appellants eng
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Background of the Case
- The case revolves around the appeal of Alvin J. Labagala and Romeo Labagala against a decision rendered by the Regional Trial Court (RTC) Branch 27 of Cabanatuan City.
- The RTC had found both appellants guilty beyond reasonable doubt of robbery with homicide, resulting in a sentence of reclusion perpetua.
- The appeal was subsequently affirmed by the Court of Appeals (CA) in a decision dated June 27, 2014.
Antecedent Facts
- Appellants, alongside co-accused Pablito Palens, Salve A. Pascual, and Michael Doe, were charged with robbery with homicide in an Amended Information dated December 23, 2002.
- The charge detailed that on June 12, 2002, in Cabanatuan City, the accused, armed with deadly weapons, violently robbed Mario P. Legaspi, Sr., resulting in his death.
- The prosecution alleged that the appellants conspired to commit the crime, qualifying it with treachery and the advantage of superior strength.
Version of the Prosecution
- The incident was witnessed by Jun Alberto, who was dining with the victim when the robbery occurred.
- Jun testified that appellants Alvin and Romeo, along with their accomplices, entered the property, with Alvin brandishing a gun and physically assaulting the victim.
- After the robbery, which involved stealing jewelry and a firearm, the victim was dragged inside the house where he was later found dead.
Version of the Defense
- The appellants raised defenses of denial and alibi.
- Romeo Labagala claimed to have been harvesting rice in Barangay Dicos, Nueva Ecija, since Ju