G.R. No. 252276 . November 11, 2021
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JERRICO JUADA Y NAVARRO, ACCUSED-APPELLANT.

FACTS

Accused-appellant Jerrico Juada y Navarro was charged with Robbery with Homicide under Article 294 of the Revised Penal Code. The information alleged that on December 18, 2011, in Bocaue, Bulacan, he, with intent to gain and by means of violence and intimidation, took cash and a pistol from Florante Garcia, and on the occasion thereof, with intent to kill and treacherously, shot and killed Garcia. Jerrico pleaded not guilty. The prosecution’s case was built on circumstantial evidence: traffic enforcer Amalia Valentin witnessed a man (wearing a white cap, red and blue jacket, and a blue handkerchief covering his face) shoot the victim and take his bags. This man later chased the witnesses. PO2 Bucco, Jr. responded and saw a man matching the description flee. Waitress Angel Bonbon testified that a man with the same attire used the comfort room of her carinderia, left bloodstains, and abandoned his cap, jacket, and handkerchief. PO3 Higoy recovered the abandoned motorcycle (borrowed by Jerrico from Marlon Geronimo) and the victim’s bags, and secured the abandoned clothing from the carinderia. Marlon Geronimo testified that Jerrico borrowed his motorcycle on the day of the incident and later apologized, saying, “Pre, bakit naman ako at pati ang motorsiklo ko ay nadamay sa ginawa mo?” Witnesses identified Jerrico from a police booking sheet. The defense presented denial and alibi, claiming Jerrico was elsewhere working on his tricycle and later drinking. The RTC convicted Jerrico based on circumstantial evidence and sentenced him to reclusion perpetua. The CA affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Jerrico Juada y Navarro for the crime of Robbery with Homicide based on circumstantial evidence.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the conviction. The prosecution successfully established an unbroken chain of circumstantial evidence consistent with the hypothesis of Jerrico’s guilt and inconsistent with innocence. The circumstances proven were: (1) Jerrico borrowed the motorcycle used in the crime; (2) a man matching his description was seen shooting the victim and taking his belongings; (3) the same man abandoned clothing in a carinderia; (4) the abandoned motorcycle and victim’s belongings were found; (5) Jerrico’s post-crime conduct, including his apologetic statement to Marlon and inquiry about the case, indicated consciousness of guilt. These circumstances, taken together, lead to a moral certainty of his guilt. The defense of denial and alibi cannot prevail over positive circumstantial evidence. The crime is Robbery with Homicide. The qualifying circumstance of treachery was correctly appreciated as a generic aggravating circumstance, warranting the imposition of the maximum penalty. Applying prevailing jurisprudence, the penalty is reclusion perpetua, without eligibility for parole. The awards for civil indemnity, moral damages, and exemplary damages are increased to ₱100,000.00 each. Actual damages of ₱110,000.00 (the amount stolen) are also awarded. All monetary awards shall earn interest at 6% per annum from finality of judgment until full payment.