GR 209227; (March, 2015) (Digest)
G.R. No. 209227, March 25, 2015
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CHARLIE OROSCO, Accused-Appellant.
FACTS
Accused-appellant Charlie Orosco, along with Abner Astor and two unidentified individuals, was charged with Robbery with Homicide. The prosecution’s case primarily relied on the eyewitness account of Albert M. Arca. Arca testified that on May 16, 2006, at around 2:00 p.m., he witnessed a verbal argument at the store of Lourdes Yap over change. Two men, one of whom he identified as Charlie Orosco, forcibly entered the store. Orosco held Yap’s hands from behind while his companion covered her mouth and stabbed her in the chest. After Yap fell, Orosco took a thick wad of bills from the base of a religious icon. The two men then fled with two lookouts. The victim died from a single stab wound. Arca initially hesitated to physically point out Orosco in open court due to fear but later positively identified him. Orosco presented an alibi, claiming he was at home in Bigaa taking care of his child at the time of the incident, which was corroborated by his wife. The Regional Trial Court convicted Orosco of Robbery with Homicide and sentenced him to reclusion perpetua, ordering him to pay civil indemnity, moral damages, and exemplary damages. The Court of Appeals affirmed the conviction.
ISSUE
1. Whether the trial court erred in giving credence to the uncorroborated eyewitness testimony of Albert Arca.
2. Whether the accused-appellant should only be held liable for robbery and not the complex crime of robbery with homicide.
RULING
The Supreme Court dismissed the appeal and affirmed the conviction.
1. The testimony of a single, credible, and trustworthy witness is sufficient to sustain a conviction. The trial and appellate courts found Arca’s testimony convincing despite his initial hesitation to point out the accused in court, which was understandable due to fear. His subsequent positive identification of Orosco was deemed credible.
2. The crime committed is the special complex crime of Robbery with Homicide. When homicide is committed by reason or on the occasion of the robbery, all those who took part in the robbery shall be guilty of the complex crime, regardless of who directly caused the death. Since the killing occurred during the commission of the robbery in which Orosco actively participated by restraining the victim and taking the money, he is liable for Robbery with Homicide. The penalty of reclusion perpetua was affirmed. The awarded damages were also affirmed, with the modification that they shall earn legal interest at 6% per annum from the finality of judgment until full payment.