People v. Constantino

G.R. No. 111124 (June 20, 1996)

Facts:

On May 15, 1988, a robbery occurred at the residence of Hichiro Kubota, a Japanese national, and his Filipino common-law wife, Elizabeth Hammond, in Makati, Metro Manila. The incident involved five armed men, including the accused-appellant Enrique Constantino, who was a former driver for Kubota. The robbers, armed with handguns and knives, entered the house, threatened the occupants, and stole valuables amounting to approximately P800,000, 26,000 yen, and US$2,400. During the robbery, Hichiro Kubota and a maid, Hazel Arjona, were fatally stabbed, while another maid, Marilyn Juguilon, was also attacked but survived.

The prosecution charged Constantino and his co-accused with robbery with homicide, alleging that they conspired to commit the crime. The trial court found Constantino guilty, while one co-accused was acquitted due to lack of evidence against him. Constantino's defense was based on the claim that he acted under duress, asserting that he was coerced by his co-accused into participating in the robbery and subsequent killings.

Legal Issues:

1. Whether the defense of duress was valid in absolving Constantino of criminal liability.
2. Whether the trial court erred in its assessment of the credibility of the prosecution witnesses.
3. The implications of conspiracy in establishing liability for the special complex crime of robbery with homicide.

Arguments:

For the Prosecution:

• The prosecution presented eyewitness testimonies from Elizabeth Hammond and other witnesses, who identified Constantino as an active participant in the robbery and the killings.
• The prosecution argued that Constantino's actions were deliberate and that he had opportunities to escape or resist but chose not to do so.
• The prosecution maintained that the evidence established a conspiracy among the accused, making all participants liable for the actions taken during the robbery, including the homicides.

For the Defense:

• Constantino claimed he acted under the impulse of uncontrollable fear, asserting that he was threatened by Salvatierra, one of his co-accused, who brandished a knife and coerced him into participating in the crime.
• The defense argued that the trial court erred in disbelieving Constantino's version of events and in favoring the testimonies of the prosecution witnesses, which they claimed were unreliable.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding Constantino guilty of robbery with homicide. The court reasoned that the defense of duress was not valid, as it did not meet the legal standards required to absolve an accused of criminal liability. The court emphasized that for duress to be a valid defense, there must be a real, imminent, and reasonable fear for one's life, which was not established in Constantino's case.

The court noted that Constantino had opportunities to dissociate himself from the crime, such as when he rang the doorbell and entered the victims' home. His claim of being coerced was deemed self-serving and contradicted by the testimonies of credible witnesses who provided detailed accounts of his involvement in the crime.

The court also addressed the issue of conspiracy, stating that the actions of the accused indicated a joint purpose and concerted action, making all conspirators liable for the consequences of their collective actions. The court reiterated that in cases of robbery with homicide, all participants are considered principals in the crime, regardless of their individual roles in the killings.

Significant Legal Principles Established:

• The defense of duress requires a credible and immediate threat to life or limb; mere fear or intimidation is insufficient.
• Conspiracy can be inferred from the actions of the accused before, during, and after the commission of the crime, establishing joint liability for the resulting offenses.
• The special complex crime of robbery with homicide encompasses all homicides committed in the course of the robbery, and the number of victims does not multiply the offense but may be considered as an aggravating circumstance.