In People of the Philippines v. Rudy and Robert Buduhan, the Supreme Court affirmed the conviction of two men for robbery with homicide, underscoring that inconsistencies in witness statements made during preliminary investigations do not automatically discredit their testimony in court. The Court emphasized that open court testimonies hold greater weight, and it reiterated that a negative paraffin test is not conclusive proof of innocence, as other factors can influence the results. This ruling reinforces the importance of comprehensive evidence evaluation in Philippine criminal law and demonstrates that while every piece of evidence is considered, inconsistencies do not automatically dismiss a witness. The court’s decision maintains the conviction, showcasing a stringent approach against those accused of serious offenses.

From Beerhouse Brawl to Justice Prevail: How Reliable is Eyewitness Testimony in Robbery-Homicide Cases?

The case revolves around an incident that occurred on July 24, 1998, at the RML Canteen in Maddela, Quirino. According to the prosecution, Robert and Rudy Buduhan, along with others, robbed patrons, which resulted in the deaths of Larry Erese and Romualde Almeron. The accused were apprehended shortly after the crime and were identified by witnesses. During the trial, Cherry Rose Salazar, a key witness, identified the Buduhans as the perpetrators. However, inconsistencies arose between her sworn statement, preliminary investigation testimony, and court testimony, particularly concerning the identities of the accused and their roles in the crime. Moreover, a paraffin test on the accused yielded negative results, which the defense argued should exonerate them.

The defense raised concerns about the credibility of the witness due to inconsistencies in her statements. They argued that the trial court erred by relying heavily on her testimony despite these discrepancies and neglecting the negative paraffin test results, which suggested the accused had not recently fired a gun. The defense also questioned the legality of the warrantless arrest, claiming the arresting officers lacked personal knowledge of the crime.

The Supreme Court addressed these arguments by affirming that testimonies in open court carry more weight than statements made during preliminary investigations. The court emphasized that preliminary investigations serve primarily to establish probable cause, not guilt beyond a reasonable doubt. As a result, Cherry Rose’s court testimony was deemed more credible. Section 13, Rule 132 of the Revised Rules on Evidence clarifies the process of impeaching a witness with prior inconsistent statements, necessitating that witnesses are given a chance to explain discrepancies. Since this was not meticulously followed during the trial regarding the witness’ identification, her credibility remained intact.

Regarding the paraffin test, the Court cited its earlier rulings, noting that paraffin tests are merely corroborative and not conclusive evidence. Several external factors, such as wearing gloves, can affect the results. The Court found no reason to overturn the lower court’s factual findings that all elements of robbery with homicide were established. The prosecution successfully proved the taking of personal property through violence and intimidation, and the deaths occurred during the robbery, thereby satisfying the elements of robbery with homicide under Article 294, paragraph 1 of the Revised Penal Code:

Art. 294. Robbery with violence against or intimidation of persons-Penalties. – Any person guilty of robbery with the use of violence against or intimidation of any person shall suffer:

1. The penalty of reclusion perpetua to death, when by reason or on occasion of the robbery, the crime of homicide shall have been committed, or when the robbery shall have been accompanied by rape or intentional mutilation or arson.

Building on this principle, the Court underscored that proving conspiracy does not always require direct evidence but can be inferred from the coordinated actions of the accused before, during, and after the crime. Their combined presence, possession of arms, simultaneous firing, and coordinated escape indicated a common design. Finally, the Court dismissed the defense’s alibi, asserting that it must be impossible for the accused to have been present at the crime scene. Instead, the accused admitted to being nearby, thereby weakening their defense.

Regarding the penalties, the Supreme Court clarified that since there were no mitigating or aggravating circumstances, reclusion perpetua was the correct penalty. However, it adjusted the award for damages, affirming the civil indemnity and moral damages, but adjusted the actual and temperate damages based on presented evidence. It acquitted the appellants of a separate homicide charge, noting that the deaths were part of the robbery with homicide charge. The Supreme Court MODIFIED the Court of Appeals decision, clarifying the application of damages for the loss sustained by the victim’s families while affirming the judgment on the special complex crime of Robbery with Homicide. The case reaffirms the judiciary’s focus on actionable facts rather than mere discrepancies to bring forth judgments founded on comprehensive evaluation.

FAQs

What was the key issue in this case?	The key issue was whether the inconsistencies in the testimony of a prosecution witness and the negative results of paraffin tests were sufficient to overturn a conviction for robbery with homicide.
What is robbery with homicide?	Robbery with homicide is a special complex crime where the taking of personal property is accompanied by violence or intimidation, resulting in death. The intention of the felon must be to rob, but the killing can occur before, during, or after the robbery.
Why was the witness’s testimony considered credible despite inconsistencies?	The court deemed her testimony credible because testimonies given in open court are given more weight, preliminary investigation processes determine probable cause rather than establish guilt. Furthermore, the process to properly impeach a witness through prior inconsistent statements was not followed thoroughly during the trial.
Are paraffin test results conclusive evidence?	No, paraffin test results are not conclusive. They are merely corroborative evidence, and factors such as the use of gloves can affect their accuracy.
What is the significance of proving conspiracy in this case?	Proving conspiracy means that all individuals involved are equally responsible for the crime, regardless of their specific actions. It demonstrates a unified purpose and intent.
What is ‘animus lucrandi’ and why is it important?	‘Animus lucrandi’ means intent to gain. It is important because it establishes that the motive behind the robbery was to unlawfully acquire the victim’s property.
How did the Court address the issue of warrantless arrest?	The Court dismissed the claim of illegal warrantless arrest, citing that even if the arrest was illegal, it does not invalidate the testimonial evidence presented in court. The evidence against the accused was deemed sufficient to uphold the conviction.
What damages were awarded in this case?	The Court ordered the appellants to indemnify the heirs of Larry Erese with civil indemnity, moral damages, and temperate damages. The heirs of Romualde Almeron were awarded civil indemnity, moral damages, and actual damages.

This case illustrates how the Philippine judicial system carefully balances the assessment of testimonies and scientific evidence in serious criminal cases. While inconsistencies and negative results raise valid questions, the ultimate decision relies on a comprehensive assessment of all evidence presented, ensuring justice is served based on the totality of circumstances. The court emphasizes a need to corroborate any alibis with solid claims while maintaining that judgments must root from substantiated evidence.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines v. Buduhan, G.R. No. 178196, August 06, 2008