GR L 34092; (August, 1974) (Digest)
G.R. No. L-34092 August 21, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VICTOR VILLAR, JR., alias JUN FRUTO and REYNALDO REPULLOSO y MONES, accused. REYNALDO REPULLOSO, accused-appellant.
FACTS
On the evening of July 20, 1969, appellant Reynaldo Repulloso, Victor Villar, Jr., and companions were drinking in Naga City. Repulloso displayed a knife. Later, Repulloso and Villar boarded a trimobile driven by 14-year-old Domingo Estay. The vehicle proceeded to Lalaguna Street. The following morning, Estay was found mortally wounded inside the trimobile, having been stabbed and robbed of his earnings and sweater. Before dying, he stated he was stabbed by two unidentified persons. Doctor Honesto Marco certified the cause of death as hemorrhage from stab wounds in the chest and abdomen.
Elmer Barcelon, a friend of Repulloso, testified that at around 6:00 a.m. on July 21, Repulloso confessed to him, stating “last night we have stabbed somebody” and demonstrated the act. William Agravante, another companion that night, corroborated that Repulloso and Villar were the last ones left with the victim. An information for robbery with homicide was filed. Villar remained at large. After trial, the Court of First Instance of Camarines Sur convicted Repulloso of robbery with homicide and sentenced him to reclusion perpetua.
ISSUE
Whether the prosecution evidence sufficiently establishes the guilt of appellant Reynaldo Repulloso for the crime of robbery with homicide.
RULING
Yes, the conviction is affirmed. The Supreme Court upheld the trial court’s finding of guilt based on circumstantial evidence and Repulloso’s own extrajudicial confession. The circumstantial evidence—comprising Repulloso’s presence with the victim, his possession of a knife, his flight, and the dying declaration of the victim identifying his assailants as two persons—constitutes an unbroken chain leading to the reasonable conclusion that Repulloso participated in the crime. Crucially, the testimony of Elmer Barcelon regarding Repulloso’s detailed confession to the stabbing was found credible and corroborative.
The Court rejected Repulloso’s defense that only his co-accused, Villar, committed the stabbing. His claim of being a mere passive spectator was inconsistent with his own admission of being present during the crime and his failure to report the incident or disassociate himself immediately. His conduct after the event indicated consciousness of guilt. The Court also modified the trial court’s appreciation of aggravating circumstances. It found that nocturnity was not deliberately sought to facilitate the crime, as the street was well-lighted. Abuse of superior strength was not conclusively proven, as no eyewitness detailed how the killing was executed. Consequently, the imposition of the death penalty was unjustified. The Court affirmed the penalty of reclusion perpetua but increased the civil indemnity to the heirs of Domingo Estay to twelve thousand pesos.