G.R. No. 133650; February 19, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAMIL MATIC y BACTAD and NORBERTO SOTELO y SORIANO, accused. RAMIL MATIC y BACTAD, accused-appellant.

FACTS

The prosecution’s case, primarily through eyewitness Jimmy Escala, established that at around 3:00 a.m. on October 12, 1994, in Pasig City, appellant Ramil Matic and three companions stopped the tricycle of Rolando Villamin. One of them took Fifty Pesos (P50.00) from Villamin, after which Matic stabbed Villamin in the chest while the others held the victim. Escala, who was driving a following tricycle, recognized Matic because his headlight illuminated the scene and he knew Matic as his brother’s friend. The medico-legal report confirmed the victim died from a single stab wound. Matic was later arrested based on Escala’s identification.
The defense was a denial and an alibi. Appellant Matic claimed he was at Imelda Park awaiting merchandise for his job at the time of the incident. He also alleged that Escala was testifying against him out of ill will due to a prior altercation where Matic caught Escala stealing an egg. Matic assailed Escala’s credibility, pointing out an inconsistency between his sworn statement, which initially named Norberto Sotelo as the stabber, and his court testimony identifying Matic as the perpetrator.

ISSUE

Whether the prosecution proved the guilt of appellant Ramil Matic for the crime of Robbery with Homicide beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the alleged inconsistency in Escala’s testimony to be minor and did not undermine his overall credibility. The sworn statement was not prepared by Escala himself, and more importantly, his clear, categorical, and consistent testimony in open court, where he positively identified Matic as the stabber, prevails over any prior extrajudicial statement. The Court emphasized that testimonial evidence carries more weight than affidavits, which are often incomplete and inaccurate. Escala had a clear view of the incident, knew the appellant beforehand, and had no proven improper motive to falsely testify.
The Court upheld the finding of conspiracy. The collective actions of Matic and his companions—stopping the victim, divesting him of money, holding him, and then stabbing him—demonstrated a community of criminal purpose. In conspiracy, the act of one is the act of all; thus, Matic is equally liable for the resulting homicide committed on the occasion of the robbery. The crime is Robbery with Homicide under Article 294(1) of the Revised Penal Code. The penalty of reclusion perpetua was correctly imposed, and the awards of civil indemnity and moral damages were affirmed. However, the award of exemplary damages was deleted as no aggravating circumstance was proven.