In the Philippines, a conviction for robbery with homicide requires solid evidence linking the accused to both the robbery and the resulting death. This case clarifies the weight of circumstantial evidence and the admissibility of a co-accused’s confession in establishing guilt beyond a reasonable doubt. The Supreme Court affirmed the conviction of Romeo Romero, emphasizing that while no one directly witnessed the crime, the combination of circumstantial evidence, including a co-accused’s confession, his presence at the scene, and the recovery of his property, sufficiently proved his involvement in the robbery with homicide.

Unraveling the Crime: Can Circumstantial Evidence Seal a Robbery-Homicide Case?

The case revolves around the gruesome robbery and killing of Purita Santos Luey in her Quezon City home. Romeo Romero, along with Pedro Francisco and Salvador Gregorio, were accused of conspiring to rob Luey’s residence, which resulted in her death. Francisco was initially apprehended and confessed, implicating Romero and Gregorio. Romero, however, pleaded not guilty, claiming he was in Sorsogon during the incident. The prosecution’s case relied heavily on circumstantial evidence, including Francisco’s confession, the medical examiner’s report, the recovery of Romero’s bullcap at the crime scene, and a witness identifying Romero leaving the victim’s house.

The critical issue before the Supreme Court was whether this collection of circumstantial evidence met the legal standard for conviction. To convict based on circumstantial evidence, the Revised Rules on Evidence require more than one circumstance, proof of the facts underlying the inferences, and a combination of circumstances that produce a conviction beyond a reasonable doubt. The defense argued that the prosecution’s evidence was insufficient, as no one directly witnessed Romero committing the crime. However, the Court disagreed, meticulously analyzing each piece of evidence to determine its probative value.

One central piece of evidence was the extrajudicial confession of Pedro Francisco. While such confessions are generally inadmissible against co-accused due to hearsay rules, the Court recognized an exception. It stated that a confession could be used as corroborative evidence to prove the existence of a conspiracy among the accused. Citing People v. Aquino, 310 SCRA 437 (1999), the Supreme Court reiterated that an extrajudicial confession is admissible only against the confessant but can corroborate other facts establishing the co-accused’s guilt. The excerpt from Francisco’s confession detailed the planning and execution of the crime, placing Romero at the scene and implicating him in the violence against Luey. This confession helped to establish the conspiracy among the accused parties.

T: Bigla na lamang pong tinutukan ni ROMEO ng ice pick si Misis at inakap ito.
Hinatak po nila si Misis sa loob ng bahay, at bigla na lamang sinaksak ni Romeo sa may pintuan ng kusina at sinuntok naman nitong si ADOR sa mukha si Misis at ng makapasok sa loob ay pinagsasaksak na nila ito sa harap at sa likod.

Further solidifying the case was the medico-legal report and testimony of Dr. Dario Gajardo, which confirmed that Purita Santos Luey died from multiple stab wounds, likely inflicted by a pointed instrument like an ice pick. This evidence aligned with Francisco’s confession, which stated that Romero used an ice pick during the attack. The presence of ice pick scabbards at the crime scene further corroborated this account. The recovery of Romero’s bullcap at the scene added another layer of circumstantial evidence linking him to the crime. Francisco’s statement, as well as the recovery of the bullcap, helped to establish a link between the accused and the crime.

Perhaps the most compelling piece of evidence was the positive identification of Romero by Carlos Obal, the victim’s cousin and gardener. Obal testified that he saw Romero and his co-accused hurriedly leaving the Luey residence with bags on the morning of the crime. The Court emphasized that positive identification does not solely rely on direct eyewitness testimony. It also includes identifying the accused at the scene of the crime around the time it occurred. The court cited People v. Gallarde, 325 SCRA 835, 849-850 (2000):

Positive identification pertains essentially to proof of identity and not per se to that of being an eyewitness to the very act of commission of the crime. There are two types of positive identification…although a witness may not have actually seen the very act of commission of a crime, he may still be able to positively identify a suspect or accused as the perpetrator of a crime as for instance when the latter is the person or one of the persons last seen with the victim immediately before and right after the commission of the crime.

Romero’s defense was alibi, claiming he was in Pilar, Sorsogon, attending a fiesta. However, the Court dismissed this defense, citing the weakness of alibi against positive identification. Moreover, the prosecution presented evidence that the fiesta dates did not coincide with the date of the crime. The Court also noted the close proximity of Romero’s residence to Francisco’s, undermining Romero’s claim that he only met Francisco in jail. Romero’s alibi did not hold weight since there was strong circumstantial evidence to suggest his guilt.

Regarding civil liabilities, the Court affirmed the indemnity for Luey’s death and funeral expenses. However, it found insufficient evidence to support the award of actual damages for the stolen jewelry, citing the lack of receipts or other proof of their existence and value. Instead, the Court awarded temperate damages, acknowledging the pecuniary loss suffered but unproven in amount. Additionally, moral damages were awarded to compensate for the emotional distress suffered by the victim’s heirs. The accused was proven guilty and had to provide indemnity for the victim’s death.

FAQs

What was the key issue in this case?	The key issue was whether the circumstantial evidence presented by the prosecution was sufficient to convict Romeo Romero of robbery with homicide beyond a reasonable doubt. The Court scrutinized the evidentiary chain to establish if it met the standard for conviction in the absence of direct eyewitness testimony.
Can a co-accused’s confession be used against another accused?	Generally, a co-accused’s extrajudicial confession is inadmissible against others due to hearsay rules. However, it can be used as corroborative evidence to prove the existence of a conspiracy among the accused, provided other evidence supports the confession.
What is the standard for circumstantial evidence in the Philippines?	Under the Revised Rules on Evidence, circumstantial evidence is sufficient for conviction if there is more than one circumstance, the facts from which inferences are derived are proven, and the combination of all circumstances produces a conviction beyond a reasonable doubt.
What weight does positive identification carry in court?	Positive identification is crucial and includes both direct eyewitness testimony and situations where a witness identifies the accused at the scene of the crime around the time of its commission. This can be sufficient even if the witness did not see the actual crime.
How is alibi viewed as a defense in criminal cases?	Alibi is considered a weak defense, especially when contradicted by positive identification of the accused. For alibi to succeed, the accused must demonstrate they were elsewhere and could not have been at the crime scene.
What are temperate damages, and when are they awarded?	Temperate damages are awarded when some pecuniary loss is proven, but the exact amount cannot be determined with certainty. They serve as a moderate compensation in situations where actual damages cannot be precisely calculated.
What types of damages were awarded in this case?	The Court awarded indemnity for the victim’s death, funeral and burial expenses, temperate damages due to the unproven amount of loss, and moral damages for the emotional distress to the victim’s heirs.
Why was the award for actual damages (jewelry) not sustained?	The award for actual damages related to the stolen jewelry was not sustained because the prosecution failed to provide competent evidence, such as receipts or appraisals, to prove the existence, value, or loss of the jewelry with reasonable certainty.

This case illustrates the critical role of circumstantial evidence in Philippine criminal law, particularly when direct evidence is lacking. While no one directly saw Romeo Romero commit the robbery and homicide, the convergence of multiple pieces of evidence—the confession of a co-accused, positive identification placing him at the scene, and the recovery of his property—established his guilt beyond a reasonable doubt. This ruling underscores that circumstantial evidence, when compelling and consistent, can be as persuasive as direct evidence in securing a conviction.

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: THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. PEDRO FRANCISCO Y ADRIANO, ROMEO ROMERO Y ASIADO, AND SALVADOR GREGORIO, G.R. No. 138022, August 23, 2001