G.R. No. 69307 October 16, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CANDIDO ROBANTE alias “Andi” and FELIX SILAWAN, JR. alias “Alex”, accused, CANDIDO ROBANTE, alias “Andi”, accused-appellant.

FACTS

On the evening of July 23, 1983, in Balilihan, Bohol, 71-year-old Clara Layao was attacked and killed inside her home. Her blind 78-year-old husband, Patricio, was present during the incident. Patricio heard his wife address someone as “Alex” (accused Felix Silawan, Jr.) and ask why he was wronging her, followed by a loud thud. He found Clara wounded and bleeding. The assailants demanded money, and Patricio pointed to a trunk containing P200, which was stolen. Before leaving, the intruders warned Patricio not to report the crime. Clara died from her injuries, which included a head wound and a broken arm. The police investigation led to the apprehension of Felix Silawan, Jr. and Candido Robante.
Both accused were charged with the complex crime of robbery with homicide. During arraignment, they initially pleaded not guilty. However, Silawan later changed his plea to guilty, implicating Robante as his co-conspirator. The trial court proceeded with the trial for Robante. The prosecution presented Patricio Layao, who identified Silawan by voice as “Alex” and testified to Robante’s presence based on hearing a different set of footsteps and the conspiratorial nature of the acts. The trial court convicted both, sentencing Silawan to an indeterminate penalty due to his minority and plea of guilty, and Robante to reclusion perpetua.

ISSUE

Whether the guilt of accused-appellant Candido Robante for the crime of robbery with homicide was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed Robante’s conviction. The Court held that conspiracy was sufficiently established. The evidence showed that Robante and Silawan acted in concert to achieve a common purpose: to rob the victims and use violence to accomplish it. Patricio Layao’s testimony, while not providing visual identification of Robante, was credible and consistent in detailing the presence of two assailants working together—one directly attacking Clara and demanding money, and the other present and participating in the ransacking. The collective actions of the accused, from the unlawful entry to the violent assault and theft, demonstrated a community of criminal design.
The Court rejected Robante’s defense of alibi, finding it weak and unsubstantiated compared to the positive evidence of conspiracy. It also modified the trial court’s ruling on aggravating circumstances. The Court held that the aggravating circumstance of dwelling should be appreciated, as the violation of the domicile was not inherent in the commission of robbery with homicide; the crime could have been committed without entering the house. With dwelling as an aggravating circumstance, the prescribed penalty for robbery with homicide (reclusion perpetua to death) would be imposed in its maximum period, which is death. However, in line with the 1987 Constitution ’s prohibition on the death penalty, the Court affirmed the penalty of reclusion perpetua as a reduction. The Court also increased the death indemnity to P30,000.