GR 69307; (October, 1989) (Digest)
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.) before a loud thud. He found her wounded and was himself threatened. The intruders demanded money, and Patricio pointed to a trunk containing P200, which they stole. Clara died from her injuries, which included a head wound and a broken arm. The police investigation led to the apprehension of Silawan, Jr. and Candido Robante.
Both were charged with the complex crime of robbery with homicide. Silawan changed his plea to guilty, implicating Robante, and was sentenced considering his minority and plea. Robante pleaded not guilty and stood trial. The Regional Trial Court convicted Robante as a co-conspirator and sentenced him to reclusion perpetua. Robante appealed, arguing the prosecution failed to prove his guilt beyond reasonable doubt and that the evidence was insufficient to establish conspiracy.
ISSUE
The main issue is whether the prosecution proved beyond reasonable doubt the guilt of accused-appellant Candido Robante for the special complex crime of robbery with homicide.
RULING
The Supreme Court affirmed the conviction. The legal logic rests on the establishment of conspiracy and the credibility of witness identification. The Court found that the prosecution successfully proved conspiracy between Robante and Silawan. The testimony of the blind victim, Patricio Layao, was deemed credible and sufficient. Although blind, he reliably identified Silawan by voice (“Alex”) and was aware of a second assailant from distinct footsteps and actions, corroborating the presence of two perpetrators. The collective actions—the attack, the demand for money, the ransacking of the house, and the joint flight—demonstrated a community of criminal design.
The Court rejected Robante’s defense of alibi, which was uncorroborated and weak compared to the positive identification of his presence. The crime was correctly classified as the special complex crime of robbery with homicide under Article 294(1) of the Revised Penal Code, as the homicide was committed by reason or on occasion of the robbery. The Court modified the trial court’s appreciation of aggravating circumstances, ruling that dwelling should have been considered aggravating since the violation of the home was not inherent to the commission of the robbery with homicide. However, given the constitutional prohibition on the death penalty, the penalty of reclusion perpetua was affirmed. The indemnity for the victim’s death was increased to P30,000.