GR 213380; (August, 2016) (Digest)
G.R. No. 213380. August 10, 2016.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ROMAN ESPIA, ACCUSED-APPELLANT, JESSIE MORANA, REX ALFARO, RODRIGO AZUCENA, JR., AND RENANTE ABISADO, ACCUSED.
FACTS
On February 21, 1991, in Barotac Viejo, Iloilo, appellant Roman Espia, together with Jessie Morana, Rex Alfaro, Rodrigo Azucena, Jr., and Renante Abisado, armed with firearms, entered the house of spouses Melberto and Estela Ganzon, declared a hold-up, and tied up the spouses and their house helpers. Appellant acted as a look-out. The robbers took cash, checks, jewelry, and other valuables. The house helpers were locked in a bathroom. The following morning, the spouses were found dead from gunshot wounds. Co-accused Rex Alfaro and Jessie Morana, upon apprehension, confessed and implicated appellant and others. Appellant denied involvement, claiming he was residing and working in Dasmariñas, Cavite since 1990 and did not know his co-accused. The Regional Trial Court convicted appellant of Robbery with Homicide, which the Court of Appeals affirmed.
ISSUE
Whether the Court of Appeals erred in affirming appellant Roman Espia’s conviction for the special complex crime of Robbery with Homicide.
RULING
No, the Court of Appeals did not err. The Supreme Court affirmed the conviction. All elements of Robbery with Homicide under Article 294(1) of the Revised Penal Code were established: (1) taking of personal property with violence or intimidation; (2) the property belonged to another; (3) the taking was with intent to gain; and (4) homicide was committed on the occasion of the robbery. Conspiracy was proven, as appellant participated in planning and acted as a look-out during the robbery, making him liable for the acts of all conspirators. Appellant’s defenses of denial and alibi were rejected for being inherently weak and uncorroborated, and could not prevail over the positive identification by eyewitnesses. The Court modified the awarded damages, increasing civil indemnity, moral damages, and exemplary damages to ₱100,000.00 each for each victim, with interest on all monetary awards.