GR 139230; (April, 2003) (Digest)
G.R. No. 139230 ; April 24, 2003
THE PEOPLE OF THE PHILIPPINES, appellee, vs. MANUEL DANIELA alias MANUEL DE LA CRUZ @ TAGALOG and JOSE BAYLOSIS y BAISAC, appellants.
FACTS
Appellants Manuel Daniela and Jose Baylosis were convicted of robbery with homicide and sentenced to death. The victim, Ronito Enero, and his common-law wife, Maria Fe Balo, were fish vendors. Appellants, acquaintances of the couple, visited their house on March 30, 1996. After a drinking session, Maria Fe and Ronito retired to their bedroom. At around 2:00 a.m., appellants, armed with a gun and a knife, entered the bedroom. They tied up Maria Fe and the household helpers, Leo Quilongquilong and Julifer Barrera. Appellants then robbed Maria Fe of cash and jewelry. Subsequently, on Manuel’s order, Jose stabbed the intoxicated and sleeping Ronito multiple times, with Manuel also participating in the attack, resulting in Ronito’s death. Manuel then raped Julifer. Before leaving, appellants warned the victims not to report the crime.
ISSUE
The core issue is whether the appellants are guilty beyond reasonable doubt of the complex crime of robbery with homicide.
RULING
Yes, the Supreme Court affirmed the conviction but modified the penalty. The prosecution successfully established all elements of robbery with homicide: (1) the taking of personal property with violence or intimidation; (2) the property belongs to another; (3) the taking is animo lucrandi; and (4) on the occasion of the robbery, homicide is committed. The testimonies of Maria Fe Balo and Leo Quilongquilong were credible, consistent, and positively identified the appellants as the perpetrators. The sequence of events proved the homicide was committed by reason or on the occasion of the robbery, as the killing occurred after the demand for money and the ransacking of the room, and was intended to eliminate a witness and facilitate the robbery. The Court found conspiracy, as the acts of Manuel in ordering the killing and Jose in executing it demonstrated a unity of purpose. However, the death penalty was reduced to reclusion perpetua due to the absence of any aggravating circumstance that was alleged and proven with certainty. The awards for civil liability were also modified in accordance with prevailing jurisprudence.