G.R. No. 92631 September 30, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILLIAM PULOC y OLA, EDDIE MORALES y ALFREDO and FRED DRUJA, accused. WILLIAM PULOC Y OLA, accused-appellant.

FACTS

Accused William Puloc, Eddie Morales, and Fred Druja were charged with Robbery with Homicide for the killing of taxi driver Rodolfo Nebrida on March 17, 1988, in Baguio City. The information alleged that on the occasion of a robbery where cash and jewelry were taken, the accused conspired to stab and kill Nebrida. Only Puloc and Morales were arrested and tried; Druja remained at large. During trial, Morales was discharged to become a state witness. The Regional Trial Court convicted Puloc of the crime and sentenced him to reclusion perpetua.
The prosecution evidence, primarily from Morales, established that on said date, he, Puloc, and Druja, after drinking, hired Nebrida’s taxi. During the ride, Druja announced a hold-up, stabbed Nebrida, and Puloc simultaneously reached for the driver’s money bag. A struggle ensued where Nebrida fought back, wounding Puloc and Morales, before the taxi crashed. Nebrida died from his injuries. Puloc and Druja fled. The trial court found Morales’ testimony credible and sufficient to prove conspiracy and Puloc’s direct participation in the robbery and homicide.

ISSUE

The core issue is whether the trial court erred in convicting accused-appellant William Puloc of the crime of robbery with homicide based on the evidence presented, particularly the credibility of the state witness and the finding of conspiracy.

RULING

The Supreme Court affirmed the conviction. The legal logic centers on the credibility of witness Eddie Morales and the existence of conspiracy. The Court held that Morales’ testimony was credible and corroborated by physical evidence, including the recovery of the victim’s belongings and the wound on Puloc’s leg inflicted by the victim during the struggle. Minor inconsistencies in Morales’ account regarding details like the specific location of the robbery were deemed inconsequential, as they are natural for witnesses to a startling event and even reinforce credibility by showing a lack of coaching.
On conspiracy, the Court ruled it was sufficiently established by the appellants’ collective and simultaneous actions. Druja’s act of stabbing the victim and Puloc’s simultaneous act of seizing the money bag demonstrated a unity of purpose and concerted effort to commit robbery, with the homicide occurring by reason or on occasion thereof. The Court emphasized that in appeals, findings of the trial court on witness credibility are accorded great respect. The crime of robbery with homicide was thus proven beyond reasonable doubt. The Court modified the award of civil indemnity to the victim’s heirs to P50,000.00 in line with prevailing jurisprudence.