GR 112977; (January, 1997) (Digest)
G.R. No. 112977 . January 23, 1997.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOEMARIE NAVALES, ALFREDO NAVALES, JR., ALBERTO NAVALES, and NEIL NAVALES, accused. ALFREDO NAVALES, JR. and ALBERTO NAVALES, accused-appellants.
FACTS
Accused-appellants Alfredo Navales, Jr. and Alberto Navales, along with two other brothers, were charged with Robbery with Homicide. The victim, Perla Robles, a school teacher, was found dead with 21 stab wounds on October 6, 1986, in Bacolod City. Her wristwatch, ring, and cash were missing. Prosecution witnesses testified that on the night of the crime, they saw the four Navales brothers near the crime scene acting suspiciously. Another witness, a neighbor, heard the victim’s cries for help and subsequently saw the four accused fleeing from the direction of the cries. The brothers were known in the community as troublemakers and drug users.
The defense presented alibi, claiming they were elsewhere during the incident. They alleged the case was fabricated due to family feud, suggesting the victim’s brother, a policeman, framed them after a prior conflict led to the death of another Navales sibling. The trial court convicted Alfredo Jr. and Alberto, sentencing them to reclusion perpetua. Their co-accused remained at large. They appealed, challenging the credibility of the prosecution witnesses and the sufficiency of the evidence.
ISSUE
Whether the guilt of accused-appellants Alfredo Navales, Jr. and Alberto Navales for the crime of Robbery with Homicide has been proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimonies of the prosecution witnesses credible, consistent, and positive. The witness who heard the cries and saw the appellants flee provided a reliable account, and his relationship to the victim’s family did not impair his credibility absent proof of improper motive. The defense of alibi was weak and could not prevail over the positive identification. The claim of frame-up was unsubstantiated.
The legal logic rests on the principle that factual findings of the trial court on witness credibility are accorded high respect. The evidence established conspiracy; the collective actions of the brothers in being at the scene and fleeing together indicated a common purpose to commit robbery and kill the victim. The number and nature of the stab wounds evidenced intent to kill. The taking of personal properties was proven, satisfying the elements of Robbery with Homicide under Article 294 of the Revised Penal Code. The Court modified the damages awarded but upheld the penalty of reclusion perpetua, there being no aggravating circumstances sufficiently proven.