GR 86390; (June, 1993) (Digest)
G.R. No. 86390 June 30, 1993
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JAIME ROSALES y ARELLANO @ GIGI, accused-appellant.
FACTS
Accused-appellant Jaime Rosales and Alberto Pebanco were charged with Robbery with Homicide for the killing of Thelma Padua-Aruelo and the taking of her Walkman transistor radio on July 17, 1984, in Pasay City. After trial, the Regional Trial Court convicted both accused and sentenced them to reclusion perpetua, with civil liabilities. Only Jaime Rosales appealed. The prosecution’s main witness was Jaime Lopeña, a cigarette vendor who testified that he saw Rosales and Pebanco stabbing the victim and then taking her radio. Lopeña reported the incident to the police. He later faced threats from a policeman, Boyet Ignacio (Rosales’s brother-in-law), and a lawyer, who pressured him to name only Pebanco. After testifying, Lopeña was found dead from gunshot wounds. Rosales and Pebanco also executed extrajudicial confessions with the assistance of a CLAO lawyer. The defense assailed Lopeña’s credibility due to alleged inconsistencies in his testimony and challenged the voluntariness of the extrajudicial confession.
ISSUE
Whether there is sufficient evidence to convict accused-appellant Jaime Rosales of the crime of Robbery with Homicide.
RULING
Yes, the conviction is affirmed. The Supreme Court found the testimony of eyewitness Jaime Lopeña credible and sufficient to establish Rosales’s guilt beyond reasonable doubt. The alleged inconsistencies in Lopeña’s testimony were minor and did not detract from the core of his account. The trial court’s assessment of witness credibility is entitled to great respect. Furthermore, Lopeña’s eventual murder after testifying tragically corroborated the veracity of his testimony and the threats against him. The Court also noted that the trial court did not rely on the extrajudicial confession for conviction, as Lopeña’s testimony alone was sufficient. However, the Court examined the confession and found it to have been voluntarily given with proper legal assistance. All elements of Robbery with Homicide as alleged in the Information were proven. The Court modified the civil liabilities: the indemnity for death was reduced from P60,000 to P50,000; moral damages were reduced from P60,000 to P15,000; and the award of P16,924.90 for actual damages was sustained. The appealed decision was AFFIRMED with these modifications.