G.R. No. 101229 January 20, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REO DALIMPAPAS PAJARES, RAMON KAPQUIAN LONGKOP, GERRY LAODENEO PAJARES and LITO MONCADA BALADAD, accused-appellants.

FACTS

Accused-appellants were charged with Robbery with Homicide. The information alleged that on September 3, 1990, in Teresa, Rizal, the four accused, conspiring and mutually aiding one another, by means of force and violence, took two wristwatches and cash amounting to P1,500.00 from spouses Alfredo and Norma Rosales. On the occasion of the robbery, accused Reo Pajares stabbed Alfredo Rosales, inflicting fatal wounds that caused his death. After trial, the Regional Trial Court convicted all accused and sentenced each to Reclusion Perpetua, with orders for civil indemnity and damages.
The prosecution evidence, primarily from eyewitness Norma Rosales (the victim’s wife), established that while she and her husband were walking home, the four appellants emerged from a bamboo grove. Reo Pajares immediately stabbed Alfredo. Appellants Gerry Pajares and Ramon Longkop then pointed knives at Norma, who was seven months pregnant, and took her wristwatch and cash. Meanwhile, appellant Lito Baladad held the fallen Alfredo, allowing Reo Pajares to stab him again, after which Baladad took Alfredo’s wristwatch. Alfredo died shortly after being taken to the hospital.

ISSUE

Whether the trial court erred in convicting the accused-appellants of Robbery with Homicide based on the credibility of the prosecution witness.

RULING

The Supreme Court affirmed the conviction. The appellants’ challenge centered on attacking the credibility of Norma Rosales, specifically questioning minor details in her testimony, such as the ownership of the stolen wristwatch and the identification of the recovered cash. The Court found these challenges immaterial. The core facts established were the forcible taking of property and the killing of Alfredo Rosales on the same occasion. The ownership of the stolen items does not negate the element of unlawful taking. The identification of the specific cash bills recovered is also not crucial, as the essential fact is that money was taken from the victims during the attack.
The Court reiterated the well-settled doctrine that the trial court’s assessment of witness credibility is accorded the highest respect on appeal, as it is in the best position to observe demeanor and conduct. Appellate courts will not disturb such findings unless it is shown that the trial court overlooked, misunderstood, or misapplied facts that would change the outcome. After a meticulous review, the Supreme Court found no such circumstance. The testimony of Norma Rosales was clear, consistent, and credible, establishing the conspiracy and the simultaneous acts of robbery and homicide. Thus, the elements of Robbery with Homicide under Article 294(1) of the Revised Penal Code were proven beyond reasonable doubt. The decision of the trial court was affirmed in toto.