GR 109760; (September, 2000) (Digest)
G.R. No. 109760; September 27, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PABLO F. EMOY alias “BUTONG” and DOMINADOR F. EMOY alias “OYE”, accused-appellants.
FACTS
On April 30, 1991, in Sultan Kudarat, accused-appellants Pablo and Dominador Emoy, along with armed companions, ambushed a service jeep of M and S Logging Company. Eyewitness Melanio Lagasan, who was about 40 meters away, saw the group firing upon the vehicle from behind a pile of logs, causing it to crash. After the shooting ceased, Lagasan saw Pablo Emoy enter the jeep and unload items, while Dominador Emoy stood guard. The assailants then fled with loot including radio transceivers and firearms. The ambush resulted in the deaths of three individuals and serious injuries to the driver, Mario Jatico, who survived and later identified the appellants as the perpetrators who approached and looted the vehicle after the attack.
The appellants were charged with Robbery with Multiple Homicide and Frustrated Homicide. They pleaded not guilty and interposed the defenses of alibi and denial, claiming they were elsewhere during the incident. The trial court convicted them of the special complex crime of Robbery with Homicide under Article 294 of the Revised Penal Code and sentenced them to reclusion perpetua. They appealed, challenging the credibility of the prosecution witnesses and the sufficiency of the evidence.
ISSUE
Whether the prosecution proved the guilt of the accused-appellants beyond reasonable doubt for the crime of Robbery with Homicide.
RULING
Yes, the Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the credibility of the prosecution witnesses, Lagasan and Jatico. Their testimonies were found to be clear, consistent, and credible, providing a positive identification of the appellants as active participants in the ambush and the subsequent robbery. The Court emphasized that the witnesses had no ill motive to falsely testify and that their narratives were corroborated on material points.
The legal logic centers on the elements of the special complex crime of Robbery with Homicide. The prosecution successfully established that a robbery was committed by means of violence or intimidation, and that the homicides and frustrated homicide were committed by reason or on the occasion of the robbery. The taking of the company properties occurred immediately after the violent attack on the jeep, unifying the criminal acts. The Court rejected the defenses of alibi and denial as weak and unsubstantiated, noting they cannot prevail over the positive identification by credible eyewitnesses. The penalty of reclusion perpetua was affirmed, but the Court modified the civil indemnities, increasing the death indemnity and moral damages for the heirs of the deceased victims in accordance with prevailing jurisprudence.