GR 132870; (May, 2002) (Digest)
G.R. No. 132870 ; May 29, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. OLEGARIO PASCUAL, JR. y MARAMAG, accused-appellant.
FACTS
On the evening of January 16, 1992, a taxicab was seen hitting a wall in Mambugan, Antipolo. The driver, Arnold Nuarin, emerged crying for help, stating he had been stabbed, before collapsing. Two men were seen fleeing from the scene. Responding barangay watchmen and police officers gave chase and apprehended Olegario Pascual, Jr., whose clothes were stained with blood. A search yielded a bloodied fan knife from his back pocket. The victim, robbed of his earnings, died from multiple stab wounds. Pascual was charged with violation of the Anti-Highway Robbery Law.
Accused-appellant pleaded not guilty, presenting an alibi. He testified he was at his supervisor’s house, over four kilometers away, when arrested by armed men. He denied owning the knife, knowing his alleged accomplice, or committing the crime, claiming he was tortured into a confession. The trial court convicted him of the special complex crime under P.D. No. 532 and sentenced him to reclusion perpetua with damages.
ISSUE
Whether the conviction of accused-appellant based on circumstantial evidence is valid.
RULING
Yes, the conviction is valid, but the crime is properly classified as robbery with homicide under the Revised Penal Code. The Supreme Court affirmed the conviction but modified the legal qualification. The prosecution successfully established an unbroken chain of circumstantial evidence leading to the inescapable conclusion of Pascual’s guilt. The circumstances—his presence at the crime scene, being seen fleeing with another man, his apprehension during the chase, the bloodied knife found in his possession, and the medico-legal findings matching the weapon—collectively point to his culpability to the exclusion of any other reasonable hypothesis.
The Court found the alibi weak and unsubstantiated, as it was not physically impossible for him to be at the crime scene. His denial and claims of torture could not prevail over the positive circumstantial evidence. However, the information essentially alleged the elements of robbery with homicide. Since the special law (P.D. No. 532) and the Revised Penal Code provision penalize the same offense, the rule that the statute later in time prevails applies. The Court thus modified the conviction to robbery with homicide under Article 294(1) of the Revised Penal Code, still punishable by reclusion perpetua. The awards of actual damages and death indemnity were affirmed, but the moral damages were deleted for lack of factual basis.