G.R. No. 120655 October 14, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JUDY SANCHEZ y BAQUIRAS, accused-appellant.

FACTS

On June 6, 1994, in San Juan, Metro Manila, accused-appellant Judy Sanchez was charged with the special complex crime of robbery with homicide. The information alleged that by means of force, violence, and intimidation, he took the wallet and necklace of Reynald Paborada, and on the occasion thereof, stabbed and killed him. Upon arraignment, Sanchez pleaded not guilty. The Regional Trial Court convicted him and sentenced him to reclusion perpetua. The prosecution’s evidence, as presented in the Appellee’s Brief, established that around 5:30 a.m., security guard Alejandro Oledan heard a loud scream, peeped through a hole, and saw Sanchez standing where the victim’s body was later found. When Oledan went out, Sanchez ran away. Sanchez was later apprehended for trespassing at a nearby orphanage. At the police station, his clothes were found with bloodstains, and the victim’s wallet, wristwatch, money, documents, necklace, and other belongings were recovered from his possession. A bloodied screwdriver was also recovered at the crime scene. The defense presented a different version, with Sanchez testifying that he merely approached the shouting victim, was wrongly pinpointed by security guards who held a grudge against him, and denied possessing the victim’s items. The trial court convicted Sanchez based on circumstantial evidence, citing his proximity to the victim, his flight, his flimsy reason for running, and his possession of the victim’s effects.

ISSUE

1. Did the trial court err in convicting the accused-appellant of robbery with homicide?
2. Did the trial court err in finding that the killing took place by reason of or on the occasion of the robbery?

RULING

The Supreme Court modified the decision of the trial court. It held that the circumstantial evidence was sufficient to prove that Sanchez killed the victim. The circumstances, taken together—his confrontation with the victim prior to the death, being the only person seen near the body, his immediate flight, his bloodstained clothing, and his possession of the victim’s personal effects shortly after the crime—formed an unbroken chain leading to the reasonable conclusion that he was the perpetrator. However, the Court found that the prosecution failed to prove that the robbery was the main purpose and that the homicide was committed by reason or on the occasion of the robbery. The evidence did not establish that the original criminal design was robbery; the taking of the property appeared to be a mere afterthought to the killing. Consequently, the special complex crime of robbery with homicide was not proven. Instead, the accused-appellant was found guilty of two distinct crimes: homicide and theft. He was sentenced to an indeterminate penalty for each crime, to be served successively, ordered to indemnify the victim’s heirs, and to return the stolen items.