People v. Pat

G.R. No. 95353-54 (March 7, 1996)

Supreme Court modified Pat and Sandoval's convictions, emphasizing eyewitness credibility and legal distinctions.

Facts:

On May 31, 1986, at approximately 1:30 AM, a group of young individuals, including Franklin Baguio, were walking in Cebu City after attending an amateur singing contest. As they walked, they were followed by two men, Raul Sandoval and Paulino Pat. The group, feeling threatened, attempted to walk faster, but the two men caught up with them. Pat, armed with a hunting knife, and Sandoval began to rob the group. Pat frisked one of the victims, Romeo Laurente, taking his wallet and wristwatch, while Sandoval attempted to rob Baguio.

During the robbery, Baguio resisted Sandoval's attempts to take his wallet. In response, Sandoval stabbed Baguio in the chest, causing severe injuries that led to Baguio's death from hemorrhage. Witness Amelito Undalok observed the incident and later identified both Sandoval and Pat as the perpetrators. Following the incident, the police arrested both men based on Undalok's identification.

The prosecution filed two separate informations against Sandoval and Pat: one for robbery with homicide (Criminal Case No. CBU-8728) and another for highway robbery under Presidential Decree No. 532 (Criminal Case No. CBU-8732). Both accused pleaded not guilty during their arraignment.

Legal Issues:

  1. Whether the trial court erred in convicting the accused of both robbery with homicide and highway robbery.
  2. Whether the evidence presented was sufficient to establish the guilt of the accused beyond a reasonable doubt.
  3. Whether the absence of motive should affect the conviction of the accused.

Arguments:

Prosecution:

  • The prosecution argued that the evidence, particularly the eyewitness testimony of Undalok, clearly established the guilt of both Sandoval and Pat. They contended that the actions of the accused constituted robbery with homicide since Baguio was killed during the commission of the robbery.
  • The prosecution maintained that the separate charge of highway robbery was valid as it involved a different victim (Laurente) and was committed in a public place.

Defense:

  • The defense contended that the accused should only be charged with robbery with homicide, arguing that the other charge was absorbed by this complex crime. They claimed that the prosecution failed to establish a motive for the crime, suggesting that only individuals with criminal backgrounds would commit such acts.
  • The defense presented alibi witnesses who claimed that the accused were not at the scene of the crime. They also argued that the eyewitness testimony was unreliable due to inconsistencies and biases.

Court's Decision and Legal Reasoning:

The trial court found both Sandoval and Pat guilty of robbery with homicide and highway robbery, imposing severe penalties. However, upon appeal, the Supreme Court modified the decision.

  1. Complex Crime of Robbery with Homicide: The Court held that while the intent to rob was established, the prosecution did not prove that Baguio's wallet was taken, leading to the conclusion that the crime committed was attempted robbery with homicide rather than robbery with homicide. The Court emphasized that for robbery with homicide to be established, the taking of property must be proven.

  2. Highway Robbery Charge: The Court ruled that the charge of highway robbery under P.D. No. 532 was improperly applied. It clarified that highway robbery requires a specific context involving multiple offenders and a broader impact on public safety, which was not present in this case. The Court concluded that the proper charge should have been simple robbery.

  3. Motive and Credibility of Witnesses: The Court noted that proof of motive is not essential for conviction if the accused is positively identified. The credibility of Undalok's testimony was upheld, and the Court found no compelling reason to doubt his account despite minor inconsistencies.

Significant Legal Principles Established:

  • The ruling clarified the distinction between robbery with homicide and attempted robbery with homicide, emphasizing the necessity of proving the actual taking of property for the former.
  • The decision also highlighted the limitations of P.D. No. 532 regarding highway robbery, establishing that the mere occurrence of a robbery on a highway does not automatically qualify as highway robbery unless specific criteria are met.
  • The case reaffirmed that motive is not a prerequisite for conviction when there is clear identification of the accused by a credible witness.