Case Summary (G.R. No. 192789)
Facts of the Case
On February 8, 1998, at approximately 6:45 p.m., the appellants, together with others, executed a hold-up at the Delos Reyes residence. Armed with guns, they restrained the occupants, demanding cash and valuables. The armed men successfully stole P10,000 in cash along with personal belongings worth P5,000 and an air gun valued at P2,800. Ngano Sugan subsequently shot Nestor Delos Reyes, who died due to multiple gunshot wounds after being rushed to the hospital by his brother Reggie Delos Reyes, who heard the gunshot and attempted to intervene.
Judicial Proceedings
The Regional Trial Court (RTC) found the appellants guilty of the special complex crime of robbery with homicide and sentenced them to reclusion perpetua on September 25, 2008. The case was appealed to the Court of Appeals (CA), which affirmed the RTC's decision on April 27, 2010, highlighting the positive identification of the appellants by the victims and the corroboration by Reggie Delos Reyes.
Elements of Offense
The Supreme Court outlined the necessary elements to establish the crime of robbery with homicide, which include: (1) the taking of another's personal property; (2) the intent to gain; (3) the use of violence or intimidation; and (4) a homicide committed by reason of or on occasion of the robbery. The Court reaffirmed that the killing may occur before, during, or after the robbery, provided the intent to rob was present.
Liability for Homicide
The Court maintained that the appellants were liable as principals in the robbery with homicide despite Ngano being the sole perpetrator of the homicide. Legal precedent indicates that all those involved in a robbery are accountable for homicides that occur during the commission of the crime, unless they actively sought to prevent the killing.
Conspiracy and Joint Responsibility
The Court established that conspiracy among the appellants was evident from their coordinated actions during the robbery. The facts illustrated that they acted in concert with a unified purpose of committing the robbery, as they entered the house together and coordinated during the commission of the crime. The prevention of Reggie from intervening further exemplified their joint endeavor.
Defense and Rejection
The appellants’ defenses of denial and alibi were rejected, with the Court noting that denial is often considered weak compared to the eyewitness identification provided by the victims. The appellants failed to establish their physical impossibility of being present at the crime scene during the incident.
Reclassification of Crime
Upon reviewing the designation of the crime, the Court clarified that robbery with homicide committed by a band is not an established legal classification. Under the Revised Penal Code, robbery with homicide is the appropriate de
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Case Overview
- The case involves an appeal from the April 27, 2010 Decision of the Court of Appeals (CA) in CA-G.R. CR-HC No. 00675-MIN.
- The CA affirmed the Regional Trial Court (RTC), Branch 26, Surallah, South Cotabato's ruling that found appellants guilty beyond reasonable doubt of robbery with homicide committed by a band.
- The appellants, Gaga Latam, Saligo Kuyan, and Kamison Akoy, were sentenced to reclusion perpetua.
Incident Details
- The robbery occurred on February 8, 1998, at approximately 6:45 PM at the residence of Fortunato Delos Reyes in Purok Roxas 1, Lamsugod, Surallah, South Cotabato.
- Five armed individuals, including the appellants, entered the Delos Reyes residence, declared a hold-up, and demanded money and valuables.
- The armed men took cash amounting to P10,000.00, personal belongings valued at P5,000.00, and an air gun worth P2,800.00.
- Ngano Sugan shot Nestor Delos Reyes after bringing him outside the house, resulting in Nestor's death from multiple gunshot wounds.
Prosecution's Case
- The prosecution charged the appellants and their accomplices with the special complex crime of robbery with homicide.
- During the trial, Fortunato and Thelma Delos Reyes, as well as their son Reggie, provided positive identification of the appellants as participants in the crime.
- The RTC found the appellants guilty and imposed penalties, including civil indemnity.
Court of Appeals Decision
- The CA affirmed the RTC's decision, emphasizing the positive identi