G.R. No. 128074 July 13, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ISA ABDUL, MINYA ABDUL, MALDIS ABDUL, INGGAT DOE, and JOWEN APPANG, accused, MINYA ABDUL, accused-appellant.

FACTS

The accused-appellant Minya Abdul, along with four others, was charged with Robbery with Double Homicide and Triple Frustrated Homicide. The prosecution alleged that on August 19, 1988, in Langil Island, Basilan, the accused, armed with firearms, conspired to attack a group of persons. The accused invited the victims, including Abraham Annudin and Annih Tanjing, to a gathering. At the location, Minya Abdul and co-accused Isa Abdul suddenly grabbed the victims’ firearms and used them to shoot Annih Tanjing and Abraham Annudin, killing them instantly. The other accused then fired at the fleeing companions—Abdulbaser Tanjiri, Idil Sahirul, and Suri Jannuh—inflicting serious wounds. The accused thereafter took the victims’ firearms, a wristwatch, and jewelry.
The Regional Trial Court convicted Minya Abdul as a principal and sentenced him to reclusion perpetua. He appealed, arguing that the prosecution witnesses’ testimonies were unreliable and inconsistent. He raised the defense of denial and alibi, claiming he was elsewhere during the incident and that the prosecution failed to conclusively prove the deaths and the certainty of the injuries sustained by the other victims.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt for the complex crime of Robbery with Double Homicide and Triple Frustrated Homicide.

RULING

The Supreme Court affirmed the conviction. The Court found the testimonies of the prosecution witnesses, particularly the victims who survived the shooting, to be credible, straightforward, and consistent on material points. They positively identified Minya Abdul as one of the assailants who initiated the attack by seizing a firearm and shooting a victim. The defense of denial and alibi cannot prevail over these positive identifications, especially as the appellant failed to prove it was physically impossible for him to be at the crime scene. The fact of death was sufficiently established through the consistent testimonies of eyewitnesses who saw the victims killed; the presentation of death certificates is not indispensable. For the frustrated homicide charges, the nature and location of the gunshot wounds sustained by the survivors, as described in their testimonies and medical certificates, were sufficient to prove the intent to kill.
The Court upheld the finding of conspiracy, evident from the accused’s coordinated and simultaneous actions in attacking the group and divesting them of their belongings. The complex crime of Robbery with Homicide under Article 294(1) of the Revised Penal Code was properly appreciated, as the homicide was committed by reason or on the occasion of the robbery. The taking of the items immediately after the killings demonstrated this nexus. The aggravating circumstances of treachery and evident premeditation were correctly considered, as the attack was sudden and the plan was executed after luring the victims. However, the penalty of reclusion perpetua was correctly imposed as the maximum penalty for the complex crime, notwithstanding the aggravating circumstances. The award of damages for the stolen items and moral and exemplary damages was sustained.