G.R. No. 69210 July 5, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GUILLERMO LAYUSO, accused-appellant.

FACTS

The accused-appellant, Guillermo Layuso, was convicted by the Regional Trial Court of Pasig for the crime of Robbery with Homicide and sentenced to death. The prosecution established that on October 14, 1980, in Pateros, Metro Manila, the house of Cesar Avila was burglarized, with items valued at P4,810.00 stolen. During the incident, Avila’s maid, Lucresia Dagsaan, was found dead from multiple stab wounds. Layuso, a former carpenter who had worked on Avila’s house, was implicated. Circumstantial evidence placed him at the scene: tricycle drivers testified that around noon on that day, they transported a man matching Layuso’s description, who was shirtless, had a hand wound and blood on his shoulder, and was carrying a conspicuously bloodstained plastic bag, away from the vicinity of the crime.
Layuso admitted to killing Dagsaan but denied committing robbery, contending he should only be liable for simple Homicide. He presented an alternative narrative of events, claiming in one instance that he and the victim were sweethearts and she attacked him upon learning he was going abroad, and in another, that she stabbed him when she suspected him of theft. The trial court found these accounts illogical and inconsistent, noting the viciousness of the multiple wounds inflicted on the victim.

ISSUE

The sole issue is whether the accused-appellant should be convicted of Robbery with Homicide or only Simple Homicide.

RULING

The Supreme Court affirmed the conviction for Robbery with Homicide but modified the penalty to reclusion perpetua in accordance with constitutional prohibitions. The Court upheld the sufficiency of circumstantial evidence to prove the complex crime. Under Rule 134, Section 5 of the Rules of Court, circumstantial evidence is sufficient for conviction when: (1) there is more than one circumstance; (2) the facts from which inferences are derived are proven; and (3) the combination of all circumstances produces conviction beyond reasonable doubt. These requirements were satisfied by the proven facts: Layuso’s prior access to the dwelling, his suspicious flight from the scene with a bloodstained bag shortly after the crime, the discovery of stolen items missing, and his incredible and contradictory explanations for the killing. The logical inference from this combination was that the homicide was committed by reason or on the occasion of the robbery. The Court found the aggravating circumstances of dwelling and disregard of the victim’s sex attendant. The indemnity to the victim’s heirs was increased to P30,000.00.