G.R. No. L-60471 May 21, 1984
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO TAYAPAD, accused-appellant.

FACTS

The accused-appellant, Reynaldo Tayapad, was convicted by the Court of First Instance of Iloilo for the crime of robbery with homicide for the killing of Quintin Franco, Sr. The prosecution’s case primarily rested on the testimony of a 12-year-old witness, Mary Jane Salvalosa. She testified that on the evening of May 22, 1980, she accompanied Tayapad to the back of the Central Philippine University garage. At his instruction, she called Franco to that location. She then hid and heard three thuds. Tayapad later rejoined her, and the following morning told her Franco was dead. Franco’s widow confirmed that cash, a ring, and a watch were missing from the victim. A witness, Steve Castillo, testified that Tayapad subsequently sold these items.
Tayapad presented a different version, claiming the homicide was committed by one Roger Angga, an alleged “virile lover” of the homosexual victim. Tayapad testified he merely acted as an intermediary to arrange a meeting between Franco and Angga. He stated he witnessed Angga argue with and then strike Franco with an iron pipe, after which he fled out of fear. He asserted that Angga took the victim’s belongings and later gave the ring and watch to him, which he then sold.

ISSUE

The core issue is whether the guilt of the accused for the crime of robbery with homicide was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found the trial court correctly gave credence to the straightforward testimony of the young prosecution witness, Mary Jane Salvalosa. Her account that only Tayapad and Franco were present at the crime scene was deemed more credible than Tayapad’s claim of a third-party assailant. The Court emphasized that if Angga were truly present, the witness would have seen him, and Tayapad would have mentioned him to her immediately after the incident, which he did not. The Court agreed with the trial court’s finding that Angga was likely a fabrication, noting the absence of any corroborating testimony and the failure of the police to locate him.
The circumstantial evidence formed an unbroken chain pointing conclusively to Tayapad’s guilt. This evidence included: (1) Tayapad’s presence with the victim at the exact time and place of the killing; (2) his immediate possession and subsequent sale of the victim’s missing ring and watch; (3) his post-facto statement to the witness about the death; and (4) the lack of credible evidence to support his alternative narrative. His possession of the stolen items shortly after the crime, unexplained by any credible source other than the robbery, firmly linked him to the homicide that facilitated the taking. The Court modified the penalty by increasing the civil indemnity to P30,000 and ordering payment of P500 for the value of the stolen articles.