Case Summary (G.R. No. 170472)
Applicable Law
The case is governed by the Revised Penal Code of the Philippines, specifically Article 294, which pertains to robbery with violence against or intimidation of persons. The elements required to establish robbery with homicide must demonstrate that the intent to rob was the primary motivation and that violence, resulting in death, occurred in the course of said robbery.
Antecedent Facts
The prosecution charged the appellants with committing robbery with homicide on June 11, 2001. The appellants, along with Roberto Barredo (who subsequently died), conspired to rob Nancy Bonifacio y Galvo and others while armed. During the robbery, Harold Herrera was shot and later died from his injuries. The appellants denied the charges and presented an alibi.
Testimony of Witnesses
The prosecution's case relied heavily on the testimonies of eyewitnesses, particularly Nancy Bonifacio and Ryan Del Rosario. Both witnesses provided detailed accounts of the events during the robbery, identifying the appellants and recounting the actions taken by them during the crime. Nancy's testimony was particularly compelling, as she was able to clearly identify the individuals as participants in the robbery and indicated their actions during the incident.
Medical Evidence
Dr. Maria Cristina B. Freyra conducted the postmortem examination on Harold Herrera, concluding that he died from a gunshot wound that caused cardio-respiratory arrest. This medical evidence supported the prosecution's claim regarding the violent nature of the robbery, establishing a direct link between the robbery and the ensuing homicide.
Defense Testimony
In contrast, the appellants provided alibi defenses asserting that they were in separate locations during the commission of the crime. However, the credibility of this alibi was called into question, as it lacked corroboration from any independent witnesses who could verify their claims.
RTC and CA Rulings
The Regional Trial Court (RTC) found the appellants guilty of robbery with homicide, sentencing them to reclusion perpetua and ordering them to pay damages to the victim's family for hospitalization, burial, and moral damages. On appeal, the Court of Appeals affirmed the RTC's decision, increasing moral damages awarded to the victim's family. The CA emphasized the clear identification of the appellants by eyewitnesses and found that the alibi presented by the defense was insufficient to negate their guilt.
Sufficient Evidence Requirement
The appellate court reaffirmed that substantial evidence was presented that met the standard of proof beyond reasonable doubt required for a criminal conviction. The weight of the eyewitness testimony, underpinned by medical evidence, established a convincing narrative of the events leading to the robbery and the homicide.
Conspiracy to Commit a Crime
The evidence demonstrated a conspiracy among the accused, as they coordinated their actions during the commission of the robbery. According to established doctrine, all conspirators are accountable for the acts committed in furtherance of the conspiracy, regardless of whether each participant directly engaged in the homicide.
Penalty
Given that the crime involved no mitigating circumstances, the court upheld the imposition of r
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Case Overview
- Court: Supreme Court of the Philippines
- Date of Decision: July 3, 2009
- G.R. No.: 170472
- Nature of the Case: Criminal case involving robbery with homicide.
- Decision: Affirmed the conviction of the appellants for robbery with homicide and imposed the penalty of reclusion perpetua.
Antecedent Facts
- Charge: The appellants were charged with robbery with homicide under an Information dated June 11, 2001.
- Incident Details: The robbery occurred in Marikina City, where the appellants, armed with guns and knives, robbed Nancy Bonifacio and her boyfriend Harold Herrera, resulting in Harold's death from a gunshot wound inflicted by Roberto Barredo, an accused who died prior to trial.
- Witnesses for Prosecution: Testimonies were provided by Dr. Maria Cristina B. Freyra (Medico-Legal Officer), Nancy G. Bonifacio (victim), and Ryan Del Rosario (another passenger).
- Defense Claims: The appellants presented alibis, claiming they were elsewhere at the time of the crime.
Prosecution Evidence
- Witness Testimonies:
- Dr. Freyra’s Findings:
- Conducted a postmortem examination on Harold Herrera.
- Cause of death was identified as cardio-respiratory arrest due to a gunshot wound.
- Nancy Bonifacio’s Account:
- Described the events leading to the robbery, identifying the appellants as participants.
- Noted that Barredo shot Harold while attempting to rob him.
- Ryan Del Rosario’s Account:
- Provided corroborative details about the robbery, including the actions of the appellants.
- Dr. Freyra’s Findings:
- Identification: Both Nancy and Ryan positively identified the appellants during the trial and in prior statements.
Defense Evidence
- Alibi Claims:
- Jojo Musa: Claimed to be asleep at home during the robbery.
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