People vs. Pinlac

G.R. No. 108919 (October 11, 1996)

Facts:

The case involves a group of individuals charged with the crime of Robbery with Homicide against Gary Salvosa, a businessman who owned a commercial building in Baguio City. On August 12, 1990, Gary was attacked and killed in his penthouse, which was also his residence. The accused, including Edgar Cordero, Ernesto Pinlac, Jimmy Salazar, and several others, conspired to rob Gary, armed with various weapons, including firearms.

On the night of the incident, Gary arrived at the GP building around 7:30 PM, where he was greeted by Cordero, the security guard on duty. After a brief interaction, Cordero and the other accused attacked Gary, tied him up, and proceeded to rob him of various items, including firearms, cash, and personal belongings. Gary was ultimately killed during the robbery, suffering multiple stab wounds.

The crime scene was chaotic, with evidence indicating a struggle. Gary's body was discovered the following morning by his son and a janitor. The police investigation led to the arrest of several suspects, including Cordero and Pinlac, who were implicated through witness testimonies and recovered stolen items.

Marlon Angco, initially one of the accused, was later discharged as a state witness and provided crucial testimony against his co-accused, detailing the planning and execution of the robbery and homicide.

Legal Issues:

1. Whether the trial court erred in discharging Marlon Angco as a state witness.
2. Whether the prosecution established the conspiracy among the accused to commit robbery with homicide.
3. Whether the defense of alibi presented by some of the accused was credible.
4. The appropriate penalties and damages to be awarded to the victim's heirs.

Arguments:

• Prosecution's Arguments:

  • The prosecution argued that the evidence, including witness testimonies and the circumstances surrounding the crime, established a clear conspiracy among the accused to commit robbery with homicide.
  • Marlon Angco's testimony was crucial as it provided insight into the planning and execution of the crime, and his discharge as a state witness was justified under the law.

• Defense's Arguments:

  • The defense contended that Marlon Angco should not have been discharged as a state witness, claiming he was the most guilty and had a significant role in the crime.
  • The defense also argued that the prosecution failed to prove the existence of a conspiracy and that the alibi presented by some accused was credible, asserting that they were not present at the scene during the commission of the crime.

Court's Decision and Legal Reasoning:

The trial court found the accused guilty of robbery with homicide, sentencing Cordero, Pinlac, Salazar, and others to reclusion perpetua, while Sales Sabadao was found liable as an accomplice. The court upheld the discharge of Marlon Angco as a state witness, determining that he did not appear to be the most guilty and that his testimony was corroborated by other evidence.

The court reasoned that conspiracy could be inferred from the actions and conduct of the accused before, during, and after the crime. The evidence showed that they acted in unison with a common criminal purpose. The defense of alibi was rejected as the accused failed to provide convincing evidence that it was physically impossible for them to be at the crime scene during the time of the robbery and homicide.

The court also addressed the computation of damages awarded to the victim's heirs, correcting the amounts for lost earning capacity and actual damages based on established legal principles.

Significant Legal Principles Established:

1. The discharge of an accused as a state witness is permissible under certain conditions, including the necessity of their testimony and the absence of them being the most guilty.
2. Conspiracy can be established through circumstantial evidence and the collective actions of the accused, rather than direct evidence of prior agreement.
3. The credibility of witness testimony is primarily determined by the trial court, which has the advantage of observing the demeanor of witnesses during their testimony.
4. The computation of damages for loss of earning capacity must adhere to established formulas and guidelines to ensure fairness to the victim's heirs.