People of the Philippines v. Domingo Baccay, G.R. No. 348 Phil. 322
### Facts:
On January 14, 1992, at approximately 8:00 AM, Domingo Baccay and Laureto Baccay visited Isabelo Jimenez’s home in San Mariano, Isabela, allegedly to collect bets for a local jueteng game. Isabelo was in a room conversing with his crippled son, Heherson, while his grandson, Gilbert Turaray, was present, massaging Heherson’s feet.
Upon entering the room, Domingo Baccay signaled to Laureto, who then attacked Isabelo with a knife. Isabelo attempted to call for help from a window but was restrained by Domingo. Heherson tried to defend Isabelo by boxing Laureto, who momentarily dropped the knife, which Domingo immediately picked up and used to stab Heherson multiple times. The two attackers then took P2,000 from Isabelo’s pocket before fleeing.
Gilbert Turaray, who had hidden behind a rocking chair, witnessed the event. Isabelo’s wife, Melchora Jimenez, upon hearing cries for help, attempted to enter the room but found it locked. She observed the attack through a hole in the wall.
Domingo Baccay admitted to being at the house but denied participating in the stabbing, claiming Laureto was the sole assailant. Nevertheless, evidence suggested Domingo’s involvement, including him reporting the incident to Wilfredo Aggabao and Manuel Gabriel.
Following a trial, the Regional Trial Court found Domingo Baccay guilty of Robbery with Homicide and sentenced him to reclusion perpetua, along with other penalties.
### Issues:
1. Whether Heherson Jimenez’s sworn statement taken by Pat. Alfonso Deraco should be considered an antemortem statement or part of the res gestae.
2. Whether the testimonies of prosecution witnesses, particularly Gilbert Turaray’s, were credible.
3. Whether Isabelo Jimenez was indeed robbed.
4. Whether there was sufficient evidence to prove conspiracy between Domingo and Laureto.
5. Whether the conviction for Robbery with Homicide was supported by the evidence beyond a reasonable doubt.
### Court’s Decision:
1. **Antemortem Statement/Res Gestae:**
– The Court held that the conviction did not rest solely on Heherson’s statement but on multiple eyewitness testimonies from Melchora, Heherson, and Gilbert, affirming Domingo’s involvement.
2. **Credibility of Witnesses:**
– The Court found the accounts of the prosecution witnesses credible. Minor inconsistencies in their testimonies were considered immaterial and did not undermine their reliability. The positive identification of Domingo by these witnesses outweighed his denials.
3. **Robbery Proof:**
– Elements of robbery with violence or intimidation and personal gain were satisfied. Gilbert’s testimony regarding the theft was clear, and although minor inconsistencies existed about the exact amount, the act of robbery was established beyond doubt.
4. **Evidence of Conspiracy:**
– The simultaneous acts, signaling between Domingo and Laureto, and corroborated witness testimonies established that there was a coordinated effort, concluding the existence of conspiracy.
5. **Conviction Beyond Reasonable Doubt:**
– The Court affirmed Domingo’s guilt beyond reasonable doubt, based on the cohesive and substantiated testimonies from multiple prosecution witnesses, combined with the circumstantial evidence.
### Doctrine:
– **Conspiracy in Criminal Acts:**
– Conspiracy can be inferred from the coordinated and aligned actions of the accused. Direct evidence is not mandatory if the concerted efforts and common purpose can be deduced from their behavior before, during, and after the criminal act.
– **Credibility of Witness Testimony:**
– Minor inconsistencies in testimonies do not undermine witness credibility if their accounts are otherwise consistent and corroborated on material facts.
### Class Notes:
– **Key Concepts for Robbery with Homicide (Art. 294, RPC):**
– Taking personal property through violence or intimidation.
– Property belongs to another.
– Intent to gain (animo lucrandi).
– Homicide occurred by reason or on occasion of the robbery.
– **Conspiracy (Art. 8, RPC):**
– Exists when a mutual agreement to commit a felony is manifest through synchronized actions.
– **Res Gestae (Rule 130, Sec. 42, Rules of Court):**
– Statements made in the spontaneity of an event can be admissible as they are part of the event.
### Historical Background:
This case transpired during a period when local numbers game (jueteng) was prevalent in the Philippines, highlighting societal issues related to illegal gambling and corresponding violence. The Supreme Court’s decision underscores the judiciary’s stance on robbery-homicide and the significance of testimonial evidence over mere denials, reflecting ongoing efforts to maintain stringent enforcement of criminal statutes.
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