G.R. No. 189850 September 22, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. REYNALDO TORRES, JAY TORRES, BOBBY TORRES @ ROBERTO TORRES y NAVA, and RONNIE TORRES, Accused, BOBBY TORRES @ ROBERTO TORRES y NAVA, Accused-Appellant.

FACTS

An Amended Information charged siblings Reynaldo, Jay, Ronnie, and appellant Bobby Torres with the special complex crime of robbery with homicide. The prosecution alleged that on September 21, 2001, in Manila, the accused, armed with bladed weapons, conspired to rob Jaime M. Espino by blocking his car, forcibly grabbing his belt-bag, and, on the occasion of the robbery, stabbing him to death and taking his personal belongings. Only appellant was arrested and arraigned. The prosecution presented eyewitnesses Eduardo Umali and Merlito Macapar, who testified that Ronnie blocked Espino’s car, struggled for his belt-bag, and was joined by his brothers, including appellant, who all stabbed Espino before taking his belongings. Dr. Romeo Salen’s medico-legal report concluded Espino died of multiple stab wounds from more than one assailant. The defense presented an alibi, with appellant claiming he was at a friend’s house drinking, and an alternative version through defense witnesses Jorna Yabut-Torres and Ditas Biescas-Mangilya, who claimed Espino was the initial aggressor who stabbed Ronnie, prompting Jay to hack Espino in retaliation. The Regional Trial Court (RTC) convicted appellant of murder, not robbery with homicide, reasoning that the element of robbery was not indubitably established and the original criminal design was not proven to be robbery. On appeal, the Court of Appeals (CA) modified the conviction to robbery with homicide, finding the intent to rob was evident from the blocking of the car and struggle for the belt-bag, and the killing was incidental.

ISSUE

Whether the Court of Appeals erred in convicting appellant of robbery with homicide instead of affirming the RTC’s conviction for murder, and whether appellant’s guilt was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the CA’s decision, with modifications to the damages awarded. The Court held that the prosecution evidence sufficiently established the special complex crime of robbery with homicide. The eyewitness accounts were credible and consistent on material points, demonstrating that the accused’s primary intent was to rob Espino, as shown by the immediate blocking of his vehicle and the attempt to seize his belt-bag upon his alighting. The killing was perpetrated by reason or on the occasion of the robbery, as the stabbing occurred when Espino resisted the robbery. The defense of alibi was weak and uncorroborated by clear and convincing evidence, and the alternative version of self-defense was unsubstantiated. The Court found conspiracy among the accused, as their collective actions showed a common purpose to commit robbery and homicide. Appellant’s liability is that of a co-principal. The penalty of reclusion perpetua was affirmed, as no aggravating or mitigating circumstances were present. The Court awarded civil indemnity, moral damages, and actual damages to the heirs of Espino, and additionally granted temperate damages and exemplary damages. All damages awarded shall earn interest at 6% per annum from the finality of the decision until fully paid.