Facts:

The case involves Larry Laurente y Bejasa, who was charged with Highway Robbery with Homicide under Presidential Decree No. 532. The incident occurred on February 14, 1994, when Herminiano Artana, a taxi driver, was found dead inside his cab. The prosecution presented evidence that Laurente and two co-accused, Melvin Dagudog and Richard Disipulo, attacked Artana, strangling him with a leather belt and striking him with a blunt object, leading to his death.

Laurente was arrested on February 15, 1994, after police found his Social Security System (SSS) ID in the victim's taxi. Witness Myra Guinto testified that she saw three men, including Laurente, leaving the taxi shortly after the incident. The trial court found Laurente guilty and sentenced him to death, along with various damages to the victim's heirs.

Legal Issues:

  1. Whether Laurente could be validly convicted of Highway Robbery with Homicide under P.D. No. 532.
  2. Whether the death penalty could be imposed given the constitutional suspension of capital punishment.
  3. Whether the prosecution proved the elements of robbery and homicide beyond reasonable doubt.

Arguments:

Prosecution:

  • The prosecution argued that Laurente and his co-accused committed robbery and homicide, as evidenced by the eyewitness testimony and the discovery of Laurente's ID in the victim's taxi.
  • They contended that the crime fell under the purview of P.D. No. 532, which penalizes highway robbery with homicide.

Defense:

  • Laurente's defense centered on the argument that the prosecution failed to prove the elements of robbery, asserting that there was no evidence of unlawful taking of property from the victim.
  • Laurente also claimed that the positive identification by the eyewitness was unreliable and that he had an alibi, stating he was at home drinking with friends at the time of the crime.

Court's Decision and Legal Reasoning:

The Supreme Court ruled that Laurente could not be validly convicted of Highway Robbery with Homicide under P.D. No. 532. The Court emphasized that the decree was intended to address acts of robbery committed indiscriminately against any person on Philippine highways, not against a predetermined victim. Since the robbery was directed at a specific individual (Artana), it did not meet the criteria for highway robbery as defined by the law.

The Court also noted that the death penalty could not be imposed due to the constitutional suspension of capital punishment, which remained in effect despite the reimposition of the death penalty for certain crimes under R.A. No. 7659. The Court found that the prosecution had not established the elements of robbery, as there was insufficient evidence to prove that the victim's earnings were unlawfully taken.

Ultimately, the Court modified the conviction to homicide under Article 249 of the Revised Penal Code, sentencing Laurente to an indeterminate penalty of imprisonment.

Significant Legal Principles Established:

  1. The distinction between robbery and highway robbery/brigandage under P.D. No. 532, emphasizing that the latter requires indiscriminate targeting of victims.
  2. The constitutional suspension of the death penalty and its implications for sentencing under laws that prescribe capital punishment.
  3. The necessity for the prosecution to prove all elements of robbery beyond reasonable doubt to sustain a conviction for robbery with homicide.