G.R. No. 131506; September 6, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODEL DIZON Y ABILA, accused-appellant.

FACTS

Accused-appellant Rodel Dizon was charged with robbery with homicide for the killing of taxi driver Juanito Baful and the taking of his personal belongings. The prosecution presented eyewitness Ricardo Asuncion, who testified that in the early morning of June 6, 1996, he was awakened by a crash and saw Dizon’s taxi had hit his fence. He observed Dizon approach the taxi, smash its windshield with a stone, and enter the vehicle. He heard the driver plead for mercy before a commotion ensued. Dizon then alighted and fled. Police investigation revealed a blood trail leading to Dizon’s house, and a security guard identified Dizon as having taken the victim’s taxi earlier. Dizon was later arrested with an improvised bladed weapon. The victim sustained 17 stab wounds.
Dizon presented a different account, claiming he was merely a bystander. He testified that after a drinking session, he was fetched by his co-accused, Raffy, who claimed to have been robbed by the taxi driver. Dizon stated he broke the windshield upon Raffy’s urging to retrieve stolen items but denied participating in the stabbing or robbery, asserting he was pulled away by his wife. The trial court convicted him of robbery with homicide and sentenced him to reclusion perpetua.

ISSUE

Whether the accused-appellant is guilty beyond reasonable doubt of the crime of robbery with homicide.

RULING

The Supreme Court modified the conviction. It found the prosecution evidence insufficient to prove the robbery component of the complex crime. The Court ruled that for robbery with homicide, the robbery itself must be conclusively established as the main purpose, and the killing must occur by reason or on the occasion of the robbery. Here, the evidence for the asportation of the victim’s watch, ring, and cash was weak, relying mainly on the son’s testimony about what the victim was last seen wearing, without proof these items were actually taken during the incident. The failure to recover these items and the lack of evidence that Dizon was seen carrying anything away from the taxi created reasonable doubt regarding the robbery.
However, Dizon’s culpability for homicide was firmly established. His own admission, corroborated by an eyewitness, that he smashed the windshield and entered the taxi where a violent struggle occurred, directly led to the killing. His flight and possession of a bladed weapon further indicated guilt. Consequently, the Court convicted him of the lesser crime of homicide. The award of damages was also modified, reducing the amounts to those supported by evidence, specifically P50,000.00 as civil indemnity and P50,000.00 as moral damages, while disallowing unsubstantiated actual damages.