GR 187073; (March, 2012) (Digest)
G.R. No. 187073 ; March 14, 2012
PEOPLE OF THE PHILIPPINES, Appellee, vs. EDUARDO CASTRO y PERALTA and RENERIO DELOS REYES y BONUS, Appellants.
FACTS
On September 9, 2002, Ricardo Pacheco Benedicto was tending his bakery supply store in Caloocan City when four armed men entered and announced a hold-up. Witness Emily Austria, a store helper, testified that appellant Eduardo Castro approached the victim’s table while appellant Renerio Delos Reyes guarded her, announcing the robbery. A commotion ensued when Benedicto resisted, prompting Delos Reyes and another assailant to join Castro. Austria fled and heard three gunshots. She saw the assailants leave, with Delos Reyes carrying the victim’s belt bag containing approximately ₱100,000. Benedicto was found dead from gunshot wounds.
Appellants were subsequently apprehended. Castro was identified by Austria and other helpers in a police line-up. Delos Reyes was likewise identified as the one who guarded Austria. They were charged with Robbery with Homicide. The Regional Trial Court convicted them, a decision affirmed by the Court of Appeals. Appellants appealed to the Supreme Court, questioning the credibility of the prosecution witness and the sufficiency of evidence for conspiracy.
ISSUE
Whether the Court of Appeals erred in affirming appellants’ conviction for the crime of Robbery with Homicide.
RULING
The Supreme Court denied the appeal and affirmed the conviction with modification. The Court upheld the factual findings of the lower courts, emphasizing that the credibility of eyewitness Emily Austria remained unshaken. Her positive identification of both appellants, detailing their specific roles during the incident, was clear and consistent. The defense of alibi proffered by the appellants was rightly rejected, as it could not prevail over this positive identification.
On the legal sufficiency of the evidence, the Court ruled that all elements of Robbery with Homicide were proven. The taking of the victim’s cash-laden belt bag through force was established. The homicide, resulting from gunshot wounds inflicted during the robbery, was an integral part of the same criminal resolution. The appellants’ collective actions—announcing the hold-up, employing armed intimidation, subduing the victim, and fleeing with the stolen property—demonstrated a community of criminal design, establishing conspiracy. Each conspirator is thus liable for the combined crime. The penalty of reclusion perpetua was affirmed. The Court modified the damages awarded, adding ₱25,000 as temperate damages to the heirs of the victim for burial expenses, which, while incurred, were not specifically proven.