G.R. No. 87236 February 8, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VICTOR TANEO y CAÑADA, alias OPAO, a certain BEBOT ESCOREAL and a certain ROY CODILLA, accused.

FACTS

Accused Victor Taneo, Roy Codilla, and Bebot Escoreal were charged with Robbery with Homicide. The information alleged that on December 22, 1986, they conspired to rob the house of Herminia Sia. Once inside, they attacked the maid, Landa Aglipa Robert, with bottles, causing her death, and stole various items valued at P13,600.00. Only Taneo and Codilla were apprehended; Escoreal remained at large. Taneo pleaded guilty and was sentenced to reclusion perpetua. Codilla pleaded not guilty, and trial ensued.
The prosecution evidence, summarized by the trial court, included: (1) Dr. Herminia Sia’s testimony that she employed Codilla as a guard but later fired him; that on the day of the crime, her neighbors apprehended the burglars; that at the police station, Taneo implicated Codilla; and that the dying maid identified Codilla as her assailant. (2) Co-accused Victor Taneo’s testimony that Codilla masterminded the robbery as revenge, provided the plan, invited the houseboy out for drinks, gave a signal, entered the house with them, boxed and struck the maid, and participated in taking the loot. Taneo also claimed Codilla’s wife offered him money in jail to save Codilla. (3) Testimonies from the arresting officer and the attending physician.
The defense presented: (1) Police Cpl. Jovito Roa, who testified that Taneo later recanted, saying Codilla was innocent and that he implicated Codilla because Dr. Sia promised him money. (2) Accused Roy Codilla’s denial, claiming he was elsewhere at the time of the crime and that Dr. Sia instigated the charge because he once stopped her from a grenade-lobbing plan. (3) Testimonies from Lolit Cabriana and Felicidad Pareño supporting Codilla’s alibi.
The trial court convicted Codilla, finding Taneo’s testimony credible and the alibi weak. Codilla appealed.

ISSUE

The main issue is whether the guilt of accused-appellant Roy Codilla for the crime of Robbery with Homicide was proven beyond reasonable doubt.

RULING

The Supreme Court AFFIRMED the conviction. The Court found the appeal devoid of merit and upheld the trial court’s decision.
The Court ruled that the testimony of co-accused Victor Taneo, corroborated by other evidence, was credible and sufficient to establish Codilla’s guilt. The Court emphasized that the testimony of an accomplice, if credible and corroborated, is admissible and can sustain a conviction. It found Taneo’s detailed account of Codilla’s planning and participation reliable. The alleged recantation reported by defense witness Roa was deemed unreliable due to inconsistencies and lack of corroboration.
The Court rejected Codilla’s alibi, noting it was not physically impossible for him to be at the crime scene. It also found the dying declaration of the victim, identifying Codilla, to be credible. The Court dismissed the defense’s theory of improper motive on the part of the complainant, finding no sufficient evidence to support it.
The penalty for Robbery with Homicide under Article 294(1) of the Revised Penal Code is reclusion perpetua to death. With no aggravating or mitigating circumstances, the penalty imposed on Codilla was reclusion perpetua. The Court modified the civil liability, ordering Codilla to indemnify the heirs of the victim P50,000.00 and to pay the value of the stolen items not recovered, with legal interest.