GR 131829; (June, 2000) (Digest)
G.R. No. 131829, June 23, 2000
People of the Philippines vs. Ronnie Agomo-o, Eddy Paneza, and Oscar Servando
FACTS
On September 22, 1993, a passenger jeepney driven by Rodito Lasap was stopped along a national highway in San Enrique, Iloilo, by three men, including accused Ronnie Agomo-o, Eddy Paneza, and Oscar Servando. Agomo-o, armed with a gun, announced a hold-up. After the driver complied with an order to turn off the engine, Agomo-o shot him, causing his death. The robbers then took cash and a wristwatch from passengers Jose Amador and Freddie Agrabio, and money from the driver. During the incident, Paneza stabbed Agrabio on the elbow. The accused-appellants, Paneza and Servando, interposed the defense of alibi, claiming they were elsewhere during the commission of the crime.
ISSUE
The core issue is whether the prosecution proved the guilt of accused-appellants Eddy Paneza and Oscar Servando for the crime of Highway Robbery with Homicide under P.D. No. 532 beyond reasonable doubt, despite their defenses of alibi and alleged inconsistencies in witness identification.
RULING
The Supreme Court affirmed the conviction. The positive identification of the accused-appellants by eyewitnesses Freddie Agrabio and Jose Amador prevails over their weak defenses. The witnesses had a clear view of the perpetrators due to moonlight and jeepney light, and their testimonies were consistent on material points. Minor inconsistencies regarding who exactly stabbed Agrabio do not undermine their credibility but instead indicate unrehearsed testimony. The defense of alibi must fail as it was not physically impossible for the appellants to have been at the crime scene. The court found conspiracy evident from the appellants’ collective and coordinated actions in stopping the vehicle, announcing the hold-up, divesting passengers of property, and employing violence.
The crime committed is Highway Robbery with Homicide under P.D. No. 532 (Anti-Piracy and Anti-Highway Robbery Law). Since homicide was committed on the occasion of the robbery, the prescribed penalty is death. However, as the crime was committed in 1993 when the death penalty was constitutionally suspended, the penalty is reduced to reclusion perpetua. The award of P50,000.00 as civil indemnity to the victim’s heirs was upheld.