G.R. No. 119696 August 18, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAZUL GUIAMIL y ANGKAT and ABEDIN MAGUID y KONTIER, accused-appellants.

FACTS

Accused-appellants Razul Guiamil and Abedin Maguid were convicted of robbery with homicide for the robbery of Lucky Jewelry Store on May 31, 1993, and the killing of employee Claude Masupil. Prosecution evidence established that Maguid smashed the store’s display window, and the appellants, with an unidentified companion, took jewelry. When Masupil attempted to pursue them, Maguid shot him. Responding policemen gave chase. SPO3 Wilfredo Salinel testified that Maguid fired at him, prompting him to return fire, hitting Maguid. A plastic bag of jewelry was recovered from Maguid. Guiamil was apprehended nearby by another officer. The appellants challenged their conviction, arguing reasonable doubt due to alleged inconsistencies in police testimonies regarding the shooting angle of Maguid and the location of Guiamil’s arrest. They also contested the identification by witnesses and the presentation of a witness not listed in the information.

ISSUE

The core issue is whether the trial court erred in convicting the appellants based on the credibility of the prosecution witnesses despite the alleged inconsistencies and identification issues raised by the defense.

RULING

The Supreme Court affirmed the conviction. The Court emphasized the settled rule that factual findings of the trial court, particularly on witness credibility, are accorded great weight and respect, as the trial judge is in the best position to observe witness demeanor and conduct. The alleged inconsistencies in the testimonies of the police officers were deemed minor and did not affect the core narrative of the crime. The positive identification by eyewitnesses Arturo Mayo and Galileo Mayo, who clearly pointed to the appellants in court as the perpetrators, was found credible and sufficient. The Court ruled that the matter of presenting witnesses is within the prosecution’s discretion, and the testimony of Galileo Mayo was properly allowed. The defense of denial was deemed inherently weak and could not prevail over positive identification. Finally, the Court upheld the conviction of both appellants for the special complex crime of robbery with homicide under Article 294(1) of the Revised Penal Code. The rule is that all principals in the robbery are liable for the homicide committed on the occasion thereof, even if only one actually perpetrated the killing. The penalty of reclusion perpetua was affirmed in the absence of aggravating circumstances.