GR 110834; (December, 1994) (Digest)
G.R. No. 110834 December 13, 1994
People of the Philippines, plaintiff-appellee, vs. Oscar Cobre, accused-appellant.
FACTS
The accused-appellant, Oscar Cobre, along with Agustin Ortiz, Papias Jaba, and Mario Carreon, were charged with Robbery with Homicide. The prosecution alleged that on October 4, 1988, in Pililla, Rizal, the group, after a dispute over unpaid wages with their employer Renato Biteranta, conspired to rob and kill him. State witness Agustin Ortiz testified that Jaba initially shot at and robbed Biteranta, after which accused-appellant Cobre shot the victim with a shotgun. Renato Guzman, another witness, heard the gunshots and later found Biteranta dead. The group then tied up Guzman and his family, stole items including a telescope and flashlight, and fled. The medico-legal report confirmed Biteranta died from multiple shotgun wounds.
The defense presented a different version, with accused-appellant denying the killing. He claimed he was forced by Carreon to hold an empty gun and tie up the Guzman family after merely discovering Biteranta’s body, asserting it was Jaba who committed the murder. The Regional Trial Court convicted Cobre of Robbery with Homicide and sentenced him to reclusion perpetua, leading to this appeal where he argues the prosecution failed to prove his guilt beyond reasonable doubt due to alleged testimonial discrepancies.
ISSUE
Whether the prosecution proved beyond reasonable doubt that accused-appellant Oscar Cobre is guilty of the special complex crime of Robbery with Homicide.
RULING
Yes. The Supreme Court affirmed the conviction. The legal logic rests on the credibility of prosecution witnesses and the nature of the complex crime. The Court found the testimonies of state witness Ortiz and eyewitness Guzman to be credible and consistent on material points, establishing that accused-appellant actively participated by shooting the victim. The medico-legal finding that the fatal wounds were from a shotgun corroborated Ortiz’s account that Cobre fired the lethal shot. The alleged minor discrepancies in the witnesses’ testimonies were deemed inconsequential to the core narrative of the crime.
The Court emphasized that denial is an inherently weak defense, especially when contradicted by positive identification. Furthermore, under the doctrine of conspiracy in Robbery with Homicide, all conspirators are liable for the homicide even if they did not personally inflict the fatal wounds, provided the killing was on the occasion or as a consequence of the robbery. Since the evidence showed a conspiracy to rob, and the homicide occurred by reason thereof, accused-appellant is liable as a principal. No evidence showed he attempted to prevent the killing. Thus, the trial court correctly convicted him of Robbery with Homicide and imposed the penalty of reclusion perpetua.