G.R. No. 90198 November 7, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO PLASENCIA y DESAMPARADO alias “Tonying,” ROBERTO DESCARTIN y PASICARAN alias “Ruby” and JOELITO (JULITO) DESCARTIN y PASICARAN, accused-appellants.

FACTS

The accused, Antonio Plasencia, Roberto Descartin, and Joelito Descartin, were charged with Robbery with Homicide. The prosecution evidence established that on November 29, 1984, the victim, Herminio Mansueto, went to Barangay Patao, Bantayan, Cebu, to buy hogs from Roberto “Ruby” Descartin, bringing cash and personal items. Eyewitness Francisca Espina saw Mansueto with Ruby at the latter’s piggery, later joined by Antonio “Tonying” Plasencia and Joelito Descartin. She witnessed Tonying stab Mansueto, followed by Ruby delivering another stab wound, while Joelito struck the victim’s forehead. The conspirators later disposed of the body at sea using a pumpboat. Mansueto’s belongings, including cash, a watch, and a bicycle, were taken.
The defense consisted of denial and alibi. Antonio Plasencia claimed he was fishing elsewhere, while Roberto Descartin alleged he was in another town. Joelito Descartin initially gave an extrajudicial confession detailing his and Tonying’s participation in killing Mansueto and dumping the body, but he later recanted this statement at trial, claiming it was coerced. The trial court convicted all three accused, sentencing them to reclusion perpetua.

ISSUE

Whether the guilt of the accused-appellants for the crime of Robbery with Homicide was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the eyewitness testimony of Francisca Espina credible, natural, and consistent. Her positive identification of the appellants, whom she knew personally, and her detailed account of the stabbing, supported by the physical evidence of bloodstains and the victim’s recovered hat at the scene, constituted proof beyond reasonable doubt. The defense of alibi was correctly rejected as it was not physically impossible for the accused to have been at the crime scene. The Court upheld the finding of conspiracy, inferred from the appellants’ collective and coordinated actions before, during, and after the killing, which demonstrated a common purpose to rob and kill the victim. The Court modified the civil indemnity to the victim’s heirs to P50,000.00 but sustained the penalty of reclusion perpetua, as the crime was committed without any aggravating or mitigating circumstances. The extrajudicial confession of Joelito, while later recanted, was consistent with the eyewitness account and other evidence, further corroborating his participation.