GR 98015; (September, 1995) (Digest)
G.R. No. 98015 September 7, 1995
People of the Philippines vs. Saturnino Dulatre, Jr., Erning Serqueña, and Manalo Maurillo, Jr.
FACTS
Saturnino Dulatre, Jr., along with Erning Serqueña and Manalo Muarillo, Jr., was charged with Robbery with Double Homicide for the killing of Rodrigo and Pedro Reyes and the taking of their personal belongings, including cash and a motorcycle, on August 12, 1988. The prosecution’s case was built primarily on circumstantial evidence. Witness Romeo Balanon testified that days before the crime, he saw appellant with two strangers who claimed to be soldiers on a mission and discussed a plan to kill individuals, including the Reyeses. On the day of the crime, witness Francisca Reyes (the victims’ wife and mother) met appellant and Muarillo on the road riding a motorcycle she recognized as her family’s. She later discovered her husband and son dead in their farmhouse, with several items missing.
ISSUE
The core issue is whether the guilt of appellant Saturnino Dulatre, Jr., for the complex crime of Robbery with Homicide has been proven beyond reasonable doubt based on circumstantial evidence.
RULING
Yes, the Supreme Court affirmed the conviction. The Court meticulously applied the rules on circumstantial evidence, which requires that: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all circumstances produces a conviction beyond reasonable doubt. The circumstances proven—appellant’s presence with the perpetrators before the crime discussing a hit list including the victims, his being seen with Muarillo on the victims’ motorcycle fleeing the crime scene shortly after the killings, and the recovery of the stolen motorcycle in his possession—form an unbroken chain leading to the fair and reasonable conclusion that he conspired in the robbery and killings. The Court found no reason to disturb the trial court’s assessment of witness credibility. The defense of denial and alibi was weak and could not prevail over the positive circumstantial evidence. The penalty was corrected to reclusion perpetua, as “life imprisonment” is not a penalty under the Revised Penal Code. The civil indemnity for the two victims was also awarded.