G.R. No. 94547 July 29, 1992
People of the Philippines vs. David Saulo y Santos

FACTS

The accused, David Saulo y Santos, was charged with Robbery with Homicide. The prosecution evidence established that on January 25, 1987, in Quezon City, the domestic helpers of the victim, Oscar Ilustre y Ilagan, heard moaning from his room. They rushed in and saw the accused on top of the victim, stabbing him with a knife. They subdued the accused, and upon frisking him, found the victim’s gold necklace with cross pendant and five 100-peso bills in his pockets. The victim sustained seventeen stab wounds, which caused his death. The accused admitted stabbing the victim but claimed it was in self-defense during a struggle after he refused the victim’s demand for anal sex. He alleged that the domestic helpers subsequently stabbed the victim further and took money, then framed him by planting the necklace and money on him.

ISSUE

Whether the trial court erred in finding the accused guilty beyond reasonable doubt, thereby violating his constitutional right to be presumed innocent.

RULING

The Supreme Court affirmed the conviction but modified the penalty and damages. The Court found the testimonies of the prosecution eyewitnesses credible and consistent, and rejected the accused’s claim of self-defense and frame-up as unsubstantiated. The crime was committed in the victim’s dwelling, which is an aggravating circumstance. Robbery with Homicide is punishable by reclusion perpetua to death. With the aggravating circumstance and considering the constitutional prohibition on the death penalty, the proper penalty is reclusion perpetua. The award of P200,000 for funeral expenses was deleted for lack of evidence, but the accused was ordered to pay P50,000 as death indemnity to the victim’s heirs.