Case Summary (G.R. No. 99355)
Statement of the Case
The case arises from an appeal by Appellants Salazar and Gotangugan from a judgment by the Regional Trial Court of Quezon City, which convicted them of robbery with homicide. The prosecution accused them, alongside an unidentified companion, of robbing security guard Crispin Gatmen and subsequently committing homicide during the incident.
Facts of the Case
On March 10, 1989, at approximately 3:30 AM, witnesses Vicente Miranda, Jr., and Pedro Soriano observed Salazar and Gotangugan, armed and with an unidentified third person, approach and assault the victim. Salazar allegedly pulled out a dagger and handed it to Gotangugan, who then stabbed Gatmen multiple times, leading to his death. The appellants were seen stealing Gatmen's firearm during the attack.
Evidence for the Prosecution
Witness testimonies detailed the sequence of events leading to the robbery and homicide. Eyewitness accounts noted the prominent lighting at the scene, allowing clear identification of the assailants. Medical findings corroborated the eyewitnesses' accounts, detailing several stab wounds on the victim.
Evidence for the Defense
In contrast, the appellants presented an alibi, claiming they were asleep at home at the time of the incident and later arrested without a warrant. They strenuously denied involvement in the crime and characterized their arrest as unlawful.
Ruling of the Trial Court
The trial court found the alibi insufficient, dismissing it as weak. It accepted the prosecution’s evidence and witness credibility, ultimately convicting both appellants of robbery with homicide, sentencing them to reclusion perpetua and imposing damages upon them.
Assignment of Errors
The appellants contended that the trial court erred in assessing the credibility of prosecution witnesses, in its overall evidence categorization, and in the handling of their alibi. They argued inconsistencies in witnesses’ testimonies and claimed improper admission of evidence due to their alleged unlawful arrest.
The Court's Ruling
Upon reviewing the case, the Court concluded that while the evidence supported convictions for homicide and theft as separate offenses, the prosecution did not establish the necessary connection to affirm the complex crime of robbery with homicide. The Court emphasized that intent to rob must be proven as the primary motive for the homicide, which was not adequately demonstrated here.
Credibility of Witnesses and Sufficiency of Evidence
The Court upheld the trial court's findings regarding witness credibility, citing that the minor inconsistencies in testimonies did not undermine the overall coherence of their statements. Both eyewitness accounts significantly corroborated each other, asserting that the identities of the assailants were adequately established.
Elements
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Background of the Case
- The case involves the appeal of Domingo Salazar y Seroma and Monchito Gotangugan y Sevilla against their conviction for robbery with homicide by the Regional Trial Court of Quezon City.
- The court ruled on April 1, 1991, that the appellants were guilty and sentenced them to suffer reclusion perpetua, alongside monetary damages to the heirs of the victim.
Statement of the Case
- The complex crime of robbery with homicide requires proof that the main purpose of the accused was the asportation of personal property, with the homicide being incidental.
- The Information filed on July 31, 1989, detailed that on March 10, 1989, the accused conspired to rob Crispin Gatmen y Ceynas of his service firearm and subsequently attacked him, leading to his death.
Facts and Evidence for the Prosecution
- Key witnesses included police officers, eyewitnesses, and medical personnel who testified to the events surrounding the robbery and murder.
- At approximately 3:30 a.m. on March 10, 1989, eyewitnesses Vicente Miranda, Jr. and Pedro Soriano observed the appellants approach the security guard, Crispin Gatmen, and initiate an attack with a dagger.
- The victim sustained multiple stab wounds, resulting in serious injury and eventual death, as confirmed by medical examinations.
Evidence for the Defense
- The defense presented alibi testimonies from both Salazar and Gotangugan, asserting that they were not present at the crime scene during the incident.
- They claimed coercion and mistreatment by police during t