G.R. No. 123299 ; September 29, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SANTIAGO CARUGAL and EFREN ESPINOSA, JR., accused, SANTIAGO CARUGAL, accused-appellant.

FACTS

On December 27, 1994, jeepney driver Leonilo Apostol was held up by four armed passengers along North Bay Boulevard in Navotas. One passenger, later identified as PO1 Fernando Salao, was stabbed. Apostol testified that he saw appellant Santiago Carugal seated behind him and co-accused Efren Espinosa, Jr. in the middle. Espinosa, Jr. snatched Salao’s service firearm. Apostol later identified Carugal and Espinosa, Jr. in a police line-up. Salao died from his wounds. The prosecution charged Carugal and Espinosa, Jr. with robbery with homicide.
The defense presented alibi and denial. Carugal claimed he was working as a porter at the Navotas Fishport at the time of the crime. Espinosa, Jr. asserted he was in Samar. They alleged they were arbitrarily arrested and forced to confess. The defense also presented news articles suggesting a different person, Joey Abarquez, killed in a separate police encounter, was responsible, as Salao’s firearm was recovered from him.

ISSUE

The core issue is whether the prosecution proved the guilt of accused-appellant Santiago Carugal for the crime of robbery with homicide beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The positive identification by eyewitness Apostol, who had a clear view of the perpetrators during the well-lit holdup, prevails over the weak defenses of alibi and denial. Apostol’s testimony was straightforward and consistent. For conspiracy, the Court ruled that direct proof is not essential; it may be inferred from the conduct of the accused before, during, and after the crime. Here, the coordinated actions of the four hold-uppers—announcing the holdup, stabbing the victim, and taking his firearm—demonstrated a community of criminal purpose. The act of one conspirator is the act of all, making Carugal equally liable for the homicide committed during the robbery.
The defense’s newspaper clippings were correctly deemed hearsay with no probative value, as the authors had no personal knowledge of the events. The recovery of the victim’s firearm from another person does not exonerate the appellant, as possession could have been transferred through various means after the crime. The trial court’s assessment of witness credibility is accorded great respect. Thus, the prosecution successfully established Carugal’s guilt beyond reasonable doubt.