G.R. No. 221427. July 30, 2018 (Case Brief / Digest)

### Title:
**People of the Philippines v. Alvin J. Labagala and Romeo Labagala**

### Facts:
On June 12, 2002, in Cabanatuan City, Alvin J. Labagala and Romeo Labagala, along with Pablito Palens and Salve A. Pascual, were accused of robbing Mario P. Legaspi, Sr. and subsequently causing his death. The Regional Trial Court (RTC), Cabanatuan City, convicted Alvin and Romeo of the crime of robbery with homicide. Their conviction was based primarily on the testimony of an eyewitness, Jun Alberto, who provided a detailed account of the incident, identifying the appellants as the perpetrators. The appellants’ defenses of denial and alibi were rejected by the RTC, and this decision was affirmed by the Court of Appeals (CA). The case proceeded to the Supreme Court on appeal.

### Issues:
The Supreme Court was tasked to decide on:
1. Whether the prosecution proved, beyond reasonable doubt, the elements of robbery with homicide, considering the reliance on the testimony of a single witness, Jun Alberto.
2. Whether the appellants acted in conspiracy in committing the crime charged.

### Court’s Decision:
The Supreme Court dismissed the appeal, upholding the CA’s decision affirming the RTC’s conviction of the appellants for robbery with homicide. The Court found Jun Alberto’s testimony to be credible and sufficient for conviction, even without corroboration by another witness. It emphasized the principle that the credibility of a witness and their testimony is generally not disturbed on appeal, especially when affirmed by both the trial court and appellate court.

The Court also held that the appellants, together with their co-accused, acted in conspiracy in committing the crime, based on their coordinated actions during the incident as described by the witness. However, the Supreme Court modified the award for damages in accordance with prevailing jurisprudence, increasing the amounts for civil indemnity, moral damages, and temperate damages, and awarding exemplary damages.

### Doctrine:
In cases of robbery with homicide, the prosecution must prove: (a) the taking of personal property with violence or intimidation; (b) the property belongs to another; (c) the taking is with intent to gain; and (d) on the occasion or by reason of the robbery, homicide is committed. The intention to commit robbery must precede the taking of human life. A single, credible witness can suffice to convict. Co-conspirators in a robbery that results in homicide are equally liable for the crime, unless it is demonstrated that they attempted to prevent the homicide.

### Class Notes:
– **Robbery with Homicide Elements:** The intent to gain (animus lucrandi) and the connection between the robbery and the homicide are key.
– **Testimony of a Single Witness:** A conviction can be based on the credible testimony of a single witness, especially if the witness has no motive to lie.
– **Conspiracy:** If a crime is committed by a group with a common purpose, each participant is equally liable, regardless of the level of their direct involvement.
– **Damages:** Modifications in damage awards align with evolving jurisprudence and aim to provide just compensation to the victims.

### Historical Background:
This case reflects the Philippine legal system’s approach to dealing with violent crimes involving robbery with homicide. It underscores the importance of eyewitness testimony in the absence of corroborating evidence and demonstrates the judiciary’s discretion in assessing witness credibility and determining damages.


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