G.R. No. 228000, July 10, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. RONALD PALEMA Y VARGAS, RUFEL PALMEA Y BAUTISTA, LYNDON SALDUA Y QUEZON, AND VIRGO GRENGIA, Accused-Appellants

FACTS

Accused-appellants were charged with robbery with homicide for the November 10, 2007, killing of Enicasio Depante at the Calamba Town Plaza. The prosecution evidence, primarily from the victim’s family, established that appellants Palema, Palmea, and Edwin Manzanero initially approached the victim. Palmea punched Enicasio to grab his cellular phone, while Palema stabbed him. Appellants Saldua and Grengia then arrived and joined in beating the victim. The victim’s son, Erickson, was prevented from helping by co-accused Lester Ladra. Enicasio died from his wounds. During trial, Manzanero died, and Ladra pleaded guilty, was convicted as a minor, and was later discharged.
The defense consisted of denial and alibi, claiming they were mistakenly identified. Ladra, however, testified for the prosecution after his plea change, narrating that the group, after drinking, attacked Enicasio upon a complaint from Palema’s girlfriend, and that they mugged the victim. Ladra explicitly stated that Grengia was not with them during the incident. The Regional Trial Court convicted all four appellants, a decision affirmed by the Court of Appeals.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of appellants for the special complex crime of robbery with homicide.

RULING

Yes, the conviction is affirmed with modification as to Virgo Grengia. For robbery with homicide, the prosecution must prove that the original intent was robbery and the killing was incidental, occurring by reason or on the occasion thereof. The testimonies of the victim’s son and stepdaughter, who witnessed the event, were found credible and consistent, positively identifying appellants and detailing the simultaneous attack and taking of the phone, thus establishing the elements of the crime.
The Court upheld the finding of conspiracy. The coordinated actions of the group—Palema and Palmea initiating the attack to seize the phone, with Saldua joining the assault—demonstrated a community of criminal design. However, the Court acquitted Virgo Grengia based on reasonable doubt. Ladra’s testimony, a co-conspirator, expressly exculpated Grengia, stating he was not part of the group that night. This testimony constituted an admission against interest and carried significant weight, creating doubt that was not sufficiently overcome by the prosecution’s evidence, which did not clearly establish Grengia’s participation. The civil indemnities awarded were also modified in line with prevailing jurisprudence.