CASE DIGEST
People v. Juada y
Navarro
G.R. No. 252276, [November 11, 2021]
FIRST, LOPEZ, M.V
Aggravating Circumstance of Treachery; Robbery with homicide
In robbery with homicide, the presence
of treachery in killing the victim is considered as a generic aggravating
circumstance in fixing the proper penalty and civil liability of the accused.
Jerrico Juada y Navarro (Jerrico) was charged with robbery with homicide before the Regional Trial Court (RTC) under Criminal Case No. 3948-M-2011. The information alleged that on December 18, 2011, in Bocaue, Bulacan, Jerrico, with intent to gain, by means of violence and intimidation, took cash and a firearm from Florante Garcia, resulting in Florante's death. Jerrico pleaded not guilty, and during the trial, the prosecution presented witnesses who testified about the incident and identified Jerrico as the perpetrator. The defense, on the other hand, presented alibi and denial as Jerrico's defenses. Jerrico was found guilty f or the crime of robbery with homicide by the RTC, relying on circumstantial evidence that formed an unbroken chain pointing to his guilt. The Court of Appeals (CA) affirmed the RTC's decision.
Whether or not the circumstantial evidence presented by the prosecution establishes Jerrico's culpability beyond reasonable doubt.
YES.
The SC noted that while none of the witnesses saw Jerrico directly commit the
crime, the cumulative effect of their testimonies formed a convincing and
unbroken chain of events leading to Jerrico's guilt. The circumstantial
evidence included eyewitness accounts of a man in specific clothing shooting
Florante and fleeing on a motorcycle, later identified as Jerrico through a
booking sheet. The police recovered Florante's belongings and the motorcycle
allegedly used in the crime, linked to Jerrico through the motorcycle owner's
testimony. Jerrico's apology to the motorcycle owner and inquiry about
Florante's case also raised suspicions about his involvement.
The SC rejected Jerrico's defenses of denial and
alibi, emphasizing the positive identification by credible witnesses and the
lack of clear and convincing proof for the defenses. Robbery with homicide is a
special complex crime, and the word “homicide” is used in its generic term,
which may include murder or parricide as long as there is incidental killing on
the commission of robbery. Furthermore, the SC clarified that the presence of
treachery is only appreciated as generic aggravating circumstances, as there
was no special complex crime of robbery with murder in the RPC. Robbery with
homicide is punishable by death. However, due to RA No. 9346, the law that
suspends the death penalty, the imposable penalty was reduced to reclusion
perpetua without eligibility for parole. The SC affirmed the CA and RTC
decisions on the penalty and civil liability, with the addition of temperate
damages.
No comments:
Post a Comment