G.R. No. 241322 , September 08, 2020
People of the Philippines, Plaintiff-Appellee, vs. Crisanto Paran y Lariosa a.k.a. “Santo,” and Leonardo F. Roelan @ “Boyax,” Accused, Leonardo F. Roelan @ “Boyax,” Accused-Appellant.

FACTS

Accused-appellant Leonardo Roelan and his co-accused Crisanto Paran were charged with Robbery with Homicide. The prosecution established that on July 23, 2010, at around 4:00 a.m., the spouses Cosme and Paula Geonson were waylaid while walking to their farm. Cosme testified that Paran suddenly struck Paula, while Roelan clubbed him, knocking out his teeth. Both assailants then searched the victims, taking P2,500.00 from Paula, before throwing them into a ravine. Paula died three days later from her injuries. The victims’ son-in-law, Hermilando Macaday, witnessed the attack and identified Paran and Roelan with the aid of his motorcycle’s headlight. The police later arrested the accused and recovered cash from them.
The defense presented alibi, claiming Roelan was elsewhere at the time. The Regional Trial Court convicted both accused of Robbery with Homicide. The Court of Appeals affirmed the conviction with modifications to the damages awarded. Roelan appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and questioning the credibility of the eyewitnesses.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant Leonardo Roelan’s conviction for the crime of Robbery with Homicide.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court found the testimonies of prosecution witnesses Cosme Geonson and Hermilando Macaday to be credible, consistent, and sufficient to establish Roelan’s guilt. Cosme positively identified Roelan, whom he knew personally, as one of his assailants, aided by his flashlight and their proximity. Macaday’s corroborative testimony, given under the light of his motorcycle headlamp, reinforced this identification. The Court emphasized that findings of trial courts on witness credibility are accorded great respect.
The elements of Robbery with Homicide were proven: (1) the taking of personal property with intent to gain; (2) the taking was accomplished with violence or intimidation; and (3) on the occasion of the robbery, homicide was committed. The killing of Paula Geonson and the taking of P2,500.00 were established. The Court ruled that conspiracy was evident from the coordinated actions of Roelan and Paran in simultaneously attacking the spouses and jointly searching them for money. The crime was properly classified as Robbery with Homicide under Article 294(1) of the Revised Penal Code. The Court modified the awarded damages in line with prevailing jurisprudence.