GR L 31401; (October, 1979) (Digest)
G.R. No. L-31401 October 30, 1979
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PEPITO VILLA, ANASTACIO SALCEDO, NORBERTO SALCEDO and ERNESTO SALCEDO, defendants-appellants.
FACTS
On the evening of June 28, 1968, Juan Acosta was killed and his wife, Dominga Domingcil Acosta, was raped in their residence in Barrio Buyon, Bacarra, Ilocos Norte. The perpetrators, pretending to be Philippine Constabulary rangers, gained entry into the house, ransacked it, stole cash and valuables, killed Juan, and raped Dominga. The accused-appellants—Pepito Villa, Anastacio Salcedo, Norberto Salcedo, and Ernesto Salcedo—were apprehended hours later on a Manila-bound bus in Badoc, Ilocos Norte. They were charged with Robbery in Band with Homicide and Rape (Criminal Case No. 5199-111) and Usurpation of Official Function (Criminal Case No. 5201-111). After a joint trial, the Court of First Instance convicted all accused of Robbery with Homicide, aggravated by rape, dwelling, nighttime, band, and craft, and sentenced them to death. They were acquitted of usurpation. The case was automatically elevated to the Supreme Court for review of the death penalty.
ISSUE
The core issue is whether the guilt of the accused-appellants for the complex crime of Robbery with Homicide, aggravated by rape, was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The legal logic rests on the conclusive establishment of the appellants’ identities as the perpetrators through the positive and credible testimony of the victim, Dominga Domingcil Acosta. The Court found her narration of the harrowing events—from the appellants’ entry by pretending to be PC soldiers, the ransacking of the house, the killing of her husband, to her own rape—to be clear, consistent, and convincing. Her testimony was corroborated by physical evidence and the prompt apprehension of the appellants while in possession of some stolen items. The defense of alibi was correctly rejected by the trial court as it could not prevail over the positive identification. The crime was correctly classified as Robbery with Homicide under Article 294(1) of the Revised Penal Code. The commission of rape during the robbery constituted a special aggravating circumstance, warranting the imposition of the supreme penalty. The Court meticulously reviewed the records and found no reason to disturb the factual findings and legal conclusions of the trial court, affirming the death penalty and the awards for civil indemnity and restitution.