GR 118670; (February, 2000) (Digest)
G.R. No. 118670 February 22, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENATO DE GUZMAN and MARCIANO RAMOS, accused-appellants.
FACTS
Accused-appellants Renato de Guzman and Marciano Ramos, along with others, were charged with Robbery with Homicide for the killing of Dr. Amadeo Belmonte and Teresa Hape and the taking of various valuables. The conspiracy was born from De Guzman’s anger after the Belmontes refused an additional payment for a water tank project and demanded a refund. During a drinking session, De Guzman, Ramos, Paquito Ancheta, and state witness Frederick Mosqueda planned the robbery. On December 2, 1992, the group, armed with a gun and a knife, entered the Belmonte residence. Dr. Belmonte was stabbed, shot, and strangled, while Teresa Hape was also killed. The group then stole cash, jewelry, and a car. The Regional Trial Court convicted De Guzman and Ramos, sentencing them to reclusion perpetua and ordering them to pay civil indemnities and damages. During appeal, De Guzman withdrew his appeal, leaving only Ramos.
ISSUE
The core issue is whether the conviction of Marciano Ramos for Robbery with Homicide is supported by evidence beyond reasonable doubt, particularly regarding his participation in the conspiracy and the proper determination of civil liability.
RULING
The Supreme Court affirmed Ramos’s conviction but modified the civil damages. Ramos’s guilt was established through the credible testimony of state witness Frederick Mosqueda, which detailed Ramos’s active participation in the planning and execution of the crime. The Court upheld the finding of conspiracy, as the collective actions of the accused, including Ramos, demonstrated a common purpose to commit robbery, which resulted in homicide. The defense of alibi was correctly rejected for being weak and unsubstantiated. Regarding civil liability, the Court recalculated the awards based on evidence. The loss of earning capacity for Dr. Belmonte was reduced to P31,320,000.00 using the standard formula. Actual damages were lowered to P113,709.75, representing duly receipted expenses. Moral damages for each set of heirs were set at P50,000.00, and exemplary damages at P20,000.00 each, in accordance with prevailing jurisprudence. The penalties of reclusion perpetua and the order for restitution were sustained.