GR 198338; (February, 2013) (Digest)
G.R. No. 198338; February 20, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. P/SUPT. ARTEMIO E. LAMSEN, P02 ANTHONY D. ABULENCIA and SPO1 WILFREDO L. RAMOS, Accused-Appellants.
FACTS
On February 19, 2001, bank manager Fernando Sy and his security guards were ambushed while returning with cash collections. Their vehicle was attacked by occupants of a white Toyota and a green Lancer, resulting in the deaths of Sy and guard Arturo Mariado. The assailants seized the money and fled. After investigation, police officers Lamsen, Abulencia, and Ramos, along with four John Does, were charged with Robbery with Homicide. The prosecution presented multiple eyewitnesses who identified the accused-appellants as the perpetrators. Investigative testimony also indicated that paint streaks and dents on the victim’s jeep matched damage found on vehicles owned by Abulencia and Ramos.
During the bail hearings, the RTC found the identification of Lamsen and Ramos by three eyewitnesses to be credible but initially deemed the testimony against Abulencia unreliable, granting his petition for bail. At trial, the accused-appellants interposed the defenses of alibi and denial. The RTC ultimately convicted all three, finding the collective eyewitness accounts credible and establishing conspiracy. The Court of Appeals affirmed the conviction with modifications to the damages awarded.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of accused-appellants for Robbery with Homicide based on the credibility of the prosecution’s eyewitnesses.
RULING
The Supreme Court denied the appeal and affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the assessment of witness credibility is best undertaken by the trial court. It ruled that the minor inconsistencies in the eyewitnesses’ testimonies pertained to collateral matters and did not detract from their core narrative, which was consistent on the material points of the crime and the positive identification of the accused-appellants. The Court noted that such minor variances even bolster credibility by negating any suspicion of rehearsed testimony.
The defenses of alibi and denial were correctly rejected for being inherently weak and insufficient to overcome the positive identification by multiple, credible witnesses who had no ill motive to falsely testify. The Court also affirmed the finding of conspiracy, as the coordinated manner of the attack—using two vehicles to overtake, shoot at, and sideswipe the victims’ jeep—demonstrated a community of criminal design. Consequently, each conspirator is liable for the crime of Robbery with Homicide as a co-principal. The awards of damages were likewise sustained in accordance with prevailing jurisprudence.