G.R. No. 82375; April 18, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BONIFACIO DOMINGO alias “Poncing”, ERNESTO CALDERON, CHARLITO PASCUAL alias “Charlie”, and DANILO PEREZ, defendants, ERNESTO CALDERON, CHARLITO PASCUAL alias “Charlie”, and DANILO PEREZ, defendants-appellants.

FACTS

On June 1, 1984, in Cabanatuan City, appellants Ernesto Calderon, Charlito Pascual, and Danilo Perez, along with an at-large co-accused, Bonifacio Domingo, entered the store-residence of septuagenarian Juanito Garcia. Posing as buyers, they then announced a robbery, poked guns at the victims, and identified themselves as NPA members. While ransacking the place for cash and valuables amounting to P100,700.00, they terrorized the household, which included Garcia’s son Renato and househelp Flora Farfaran. During the ordeal, Juanito Garcia, out of extreme fear, collapsed, complained of dizziness, and died. The autopsy later confirmed the cause of death as “Cardio Respiratory Arrest secondary to Cerebro Vascular Accident.”
After trial, the Regional Trial Court convicted the three apprehended accused of Robbery with Homicide under Article 294(1) of the Revised Penal Code. The court sentenced each to reclusion perpetua and ordered them to indemnify the heirs P100,700.00, but limited each appellant’s liability to one-fourth, reserving a share for the at-large accused. The appellants appealed, challenging the credibility of the prosecution witnesses, Renato Garcia and Flora Farfaran.

ISSUE

Whether the testimonies of the prosecution witnesses are credible and sufficient to sustain the conviction for Robbery with Homicide.

RULING

Yes, the conviction is sustained. The Supreme Court affirmed the trial court’s assessment of witness credibility, noting that minor inconsistencies in the testimonies of Renato Garcia and Flora Farfaran on collateral matters did not impair their core narrative of the robbery and the events leading to the victim’s death. These discrepancies, in fact, indicated honest and unrehearsed declarations. On the substantive law, the Court clarified the nature of Robbery with Homicide. It is immaterial that the death resulted from a heart attack induced by fright during the robbery. The law only requires that the homicide be produced by reason or on the occasion of the robbery; the specific cause or intervening mode of death is irrelevant. Thus, the appellants were correctly held liable for the complex crime.
The penalty of reclusion perpetua was proper. The mitigating circumstance of lack of intent to commit homicide was correctly offset by the aggravating circumstance of dwelling. However, the Court modified the civil liabilities. The appellants are solidarily liable for the total amount of P130,700.00, which includes the value of the stolen property (P100,700.00) plus P30,000.00 as civil indemnity for Garcia’s death, in accordance with prevailing jurisprudence. The order for subsidiary imprisonment was deleted, as it does not apply when the principal penalty is reclusion perpetua. The judgment was affirmed with these modifications.