**Facts:**
On September 23, 1987, Violeta Parnala and her common-law husband, Clark Din, returned home around 8:30 PM from the Kingdom Hall of Jehovah’s Witnesses. After several attempts to get a response from within their home in Cavite City, Violeta identified three men rushing out from their garage. Among these men, she recognized Florentino Bracamonte, Ernie Lapan, and Manuel Reginaldo. Once inside their home, the couple found devastating evidence of a crime: their son, Jay Vee Parnala Custodio, and their maid, Teresita M. Rosalinas, were brutally murdered; Violeta’s son was drowned in a pail of water, and the maid was tied, gagged, and stabbed.
An Information was filed against Florentino Bracamonte, Manuel Reginaldo, and Ernie Lapan for the crime of Robbery with Double Homicide alleging conspiracy and intent to gain marked by violence and intimidation. Each accused was supposed to have had a role in the incident that led to the deaths of Jay Vee and Teresita during or after the robbery. Bracamonte was arrested much later, in 1989, after being at large for two years. In 1989, he entered a plea of “not guilty.”
At the Regional Trial Court of Cavite City, Branch XVII, the trial concluded with a guilty verdict for Florentino Bracamonte for robbery with double homicide in 1990. He was sentenced to reclusion perpetua and required to indemnify the heirs of the victims.
**Issues:**
1. Whether the positive identification of Bracamonte by prosecution witness Violeta Parnala was credible.
2. Whether the circumstantial evidence was sufficient to affirm Bracamonte’s guilt.
3. Whether Bracamonte’s defense of alibi and lack of motive to flee could be effectively used to overturn his conviction.
4. Whether his conviction should reflect robbery with homicide rather than robbery with double homicide.
**Court’s Decision:**
1. **Positive Identification:**
The Supreme Court upheld the trial court’s acceptance of Violeta Parnala’s testimony. Despite Bracamonte’s argument that their acquaintance was too limited for her to reliably identify him, the court emphasized Violeta’s firm, credible identification made under conditions where she was in close proximity to the accused during the incident.
2. **Circumstantial Evidence:**
Circumstances established included: Bracamonte’s presence at the crime scene, his immediacy in fleeing the scene, and subsequent evasion of arrest. It was determined that all these provided sufficient basis for confirmation of his involvement per established requisites for a conviction based on circumstantial evidence.
3. **Defense of Alibi and Flight:**
Appellant’s alibi was found unconvincing as it failed to prove it was physically impossible for him to have been at the crime scene. The Supreme Court further noted that the defendant was apprehended two years post-crime, alluding to his concealment rather than taking it as evidence of innocence.
4. **Classification as Robbery with Homicide:**
The Court modified the conviction to robbery with homicide, maintaining the reclusion perpetua sentence but adjusting the legal terminology to align with the Penal Code. The number of homicides during the commission of robbery does not change the nature of the crime charged under Article 294(1) of the then-applicable Revised Penal Code.
**Doctrine:**
1. Positive identification prevails over alibi.
2. Circumstantial evidence can suffice for conviction when demonstrated beyond reasonable doubt.
3. Multiple killings during robbery qualify as robbery with homicide, not distinct from an instance involving a single homicide, which affects sentencing under historical penal codes before RA 7659.
**Class Notes:**
– **Elements of Circumstantial Evidence:**
1. Multiple circumstances must be established.
2. Facts lead to inference of guilt.
3. Appropriately warrants need for fair deduction of guilt beyond doubt.
– **Defense of Alibi:**
– Must demonstrate impossibility of presence.
– Typically less credible in light of positive identification.
– **Impact of Prior Legislation on Sentencing:**
– Penalty based on law extant at crime commission.
– Pre-RA 7659 crimes received penalties of reclusion perpetua.
**Historical Background:**
The case emerged in a period marked by strict adherence to the Revised Penal Code of the Philippines prior to amendment by R.A. 7659, which reinstated the death penalty for certain heinous crimes effective December 1993. During its trial and decision phases, the approach lent emphasis to positive identification even amid circumstances where procedural improvements like DNA evidence remained unavailable in the jurisdiction.
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