G.R. No. 233659, December 10, 2019
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOHN SANOTA Y SARMIENTO, DEO DAYTO Y GENORGA @ “RUBROB” AND ROLANDO ESPINELI Y ACEBO @ “LANDOY,” accused-appellants.

FACTS

On March 31, 2011, around 4:00 p.m., Santiago Abion, Jr. witnessed accused-appellants John Sanota, Deo Dayto, and Rolando Espineli having a drinking spree near his house. He overheard them planning to raid a house in Hacienda 8 and stating that anyone who blocks their path would be killed. Later that evening, Espineli invited Abion to a supposed birthday party in Don Jose, Santa Rosa, Laguna. Abion agreed and rode Espineli’s motorcycle. Instead of going to the party, Espineli parked the motorcycle in front of the house of Don Alfonso Quiros in Hacienda 8. Espineli entered the house, claiming he needed to talk to a fellow security guard. Shortly after, Sanota and Dayto arrived and also entered the house. Abion followed and, from a distance of 20 meters, saw Espineli hand a gun to Dayto, who then climbed through a window. After five minutes, Abion heard a gunshot and saw Dayto exit the window holding a gun and a “black thing.” Sanota and Dayto fled to the forest, while Espineli returned to the motorcycle. Abion pretended not to have witnessed the incident and was later dropped off by Espineli, who told him to keep quiet. The next day, Abion learned that the Quiros residence had been robbed and that Jose Miguel Quiros, the son of the owner, was killed. Abion later executed a sworn statement detailing the events.
An Information was filed charging appellants with Robbery with Homicide under Article 294 of the Revised Penal Code, alleging that they conspired to rob the Quiros residence and, on the occasion thereof, Dayto shot and killed Jose Miguel Quiros, stealing an Asus laptop worth P27,000.00. The prosecution presented witnesses including Abion, Lee Won Young (a friend of the victim who was present during the incident and heard the gunshot), police investigators, and security agency employees. Appellants interposed the defenses of denial and alibi, claiming they were elsewhere during the incident.
The Regional Trial Court (RTC) found appellants guilty beyond reasonable doubt of Robbery with Homicide and sentenced them to reclusion perpetua, ordering them to pay actual damages, death indemnity, moral damages, exemplary damages, attorney’s fees, and costs. The Court of Appeals (CA) affirmed the RTC decision, holding that circumstantial evidence sufficiently established appellants’ guilt. Appellants appealed to the Supreme Court, arguing that the prosecution failed to prove their guilt beyond reasonable doubt, that the testimony of Abion was incredible, and that the award of attorney’s fees lacked basis.

ISSUE

1. Whether the prosecution proved the guilt of the accused-appellants beyond reasonable doubt for the crime of Robbery with Homicide based on circumstantial evidence.
2. Whether the testimony of prosecution witness Santiago Abion, Jr. is credible.
3. Whether the award of attorney’s fees is proper.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the decision of the Court of Appeals.
1. Proof of Guilt Beyond Reasonable Doubt: The Court held that the prosecution established appellants’ guilt through circumstantial evidence, which met the required standards under Rule 133, Section 4 of the Rules of Court. The circumstantial evidence consisted of: (a) Abion overhearing appellants planning the robbery and threatening to kill anyone in their way; (b) Espineli luring Abion to the crime scene under false pretenses; (c) Abion witnessing Espineli hand a gun to Dayto, who then entered the house through a window; (d) the gunshot heard by Abion and Lee Won Young; (e) Dayto exiting the window with a gun and a “black thing”; (f) appellants fleeing immediately after; and (g) the discovery of the robbery and homicide. These circumstances formed an unbroken chain leading to the reasonable conclusion that appellants committed the crime. The Court deferred to the trial court’s factual findings and credibility assessments, which were affirmed by the CA, noting no oversight or misconstruction of evidence.
2. Credibility of Witness: The Court found Abion’s testimony credible, consistent, and corroborated by other evidence. His detailed account, including the planning stage, execution, and aftermath, was deemed reliable. The Court rejected appellants’ claim that Abion’s testimony was incredible, emphasizing that trial courts are in the best position to evaluate witness credibility. Abion’s initial reluctance to come forward did not undermine his testimony, as it was explained by fear and the prodding of his wife, who worked for the victim’s family.
3. Award of Attorney’s Fees: The Court DELETED the award of attorney’s fees for lack of factual and legal basis. The prosecution did not present evidence to justify such an award, and the trial court failed to cite any legal ground under Article 2208 of the Civil Code. However, the Court upheld all other damages awarded by the lower courts, including actual damages, death indemnity, moral damages, and exemplary damages, as these were sufficiently proven and in line with jurisprudence.
The Supreme Court affirmed appellants’ conviction for Robbery with Homicide under Article 294 of the Revised Penal Code, sentencing them to reclusion perpetua and ordering them to pay the heirs of Jose Miguel Quiros actual damages (P383,764.65), death indemnity (P75,000.00), moral damages (P1,000,000.00), exemplary damages (P200,000.00), and costs of suit. The award of attorney’s fees was deleted.