GR 241248; (June, 2021) (Digest)
G.R. No. 241248 , June 23, 2021
People of the Philippines, Plaintiff-Appellee, vs. Renato De Guzman, Romeo Cabico, Michael Domingo, Renelito Valdez, Bringle Balacanao and Boboy Tamonang, Accused. Michael Domingo and Bringle Balacanao, Accused-Appellants.
FACTS
Accused-appellants Michael Domingo and Bringle Balacanao, along with others, were charged with the special complex crime of Robbery with Homicide, aggravated by Rape, under an Amended Information. The prosecution alleged that on April 2, 2007, in Ramon, Isabela, the accused, acting in conspiracy, armed with firearms and a bladed instrument, robbed spouses AAA and BBB of cash and a wristwatch. On the occasion of the robbery, Valdez raped AAA, and BBB was shot and killed. The Regional Trial Court (RTC) convicted accused-appellants Domingo and Balacanao, as well as Renelito Valdez, and sentenced them to reclusion perpetua and damages. The Court of Appeals (CA) affirmed the RTC decision. Domingo and Balacanao appealed to the Supreme Court, arguing that the prosecution failed to prove their identity, participation, and the existence of conspiracy, and that the testimony of the main witness, AAA, was doubtful and inconsistent. Their defenses were denial and alibi.
ISSUE
Whether the prosecution proved beyond reasonable doubt the guilt of accused-appellants Michael Domingo and Bringle Balacanao for the special complex crime of Robbery with Homicide, aggravated by Rape, specifically concerning their identity, participation, and the existence of conspiracy.
RULING
The Supreme Court REVERSED and SET ASIDE the CA Decision and ACQUITTED accused-appellants Michael Domingo and Bringle Balacanao. The Court held that the prosecution failed to prove their guilt beyond reasonable doubt.
The Court found that the testimony of the lone eyewitness, AAA, did not sufficiently establish the identity and participation of Domingo and Balacanao in the crime. AAA’s testimony was inconsistent and unclear regarding who was present inside and outside the house during the incident. She did not categorically state that Domingo and Balacanao were among the perpetrators inside the house or that they performed any overt act in furtherance of the robbery, rape, or killing. Her testimony only indicated that after the shooting, she saw the assailants, including Domingo and Balacanao, running away together. The Court ruled that mere presence at the scene of the crime and flight, without more, do not constitute conspiracy. Conspiracy requires proof of an agreement to commit a crime and a deliberate participation in the execution of the crime with a view to the furtherance of the common design. The evidence did not show that Domingo and Balacanao had any prior agreement or performed any act demonstrating a common criminal purpose with the principal perpetrators (Valdez, Cabico, De Guzman, and Tamonang). Their acquittal was based on reasonable doubt. The Court directed their immediate release unless detained for another lawful cause.