In People vs. Dinamling, the Supreme Court affirmed the conviction of the accused for robbery with homicide, emphasizing the importance of positive identification by witnesses and the failure of the defense to provide a credible alibi. The court underscored that when a robbery results in death, all those who participated in the robbery are also guilty of homicide, even if they did not directly cause the death, unless they actively tried to prevent it. This decision serves as a reminder that participants in a robbery can be held liable for resulting deaths, highlighting the severe consequences of engaging in violent crimes.

Justice for Pajarrillo: How the Dinamling Case Upholds Eyewitness Testimony in Robbery-Homicide Convictions

The case stemmed from an incident on June 8, 1995, in Cordon, Isabela, where Orlando Dinamling, Fernando Dinamling, Jacinto Linnam, and Jose Dinamman were accused of robbing the house of Charlie and Marilyn Pajarillo. During the robbery, Deogracias Acosta and Rogelio Malalay were killed. The accused were charged with robbery with double homicide. At trial, the prosecution presented several witnesses, including Marilyn and Charlie Pajarillo, who positively identified the accused as the perpetrators. Rosemarie Malalay also corroborated Marilyn’s account.

The Regional Trial Court (RTC) of Santiago City found the accused guilty beyond reasonable doubt and sentenced them to death. The accused appealed, arguing that the prosecution failed to prove their guilt beyond reasonable doubt and that the homicide was not committed on the occasion of the robbery. The Supreme Court (SC) reviewed the case, focusing on the credibility of the witnesses and the sufficiency of the evidence. The Court emphasized the importance of positive identification by victims of criminal violence. It stated that victims tend to remember the faces and features of their attackers. The Court found that Marilyn and Charlie Pajarillo provided credible and consistent testimonies that positively identified the accused. The absence of ill motive from the prosecution witnesses to falsely accuse the defendants further bolstered the credibility of the prosecution’s case.

The Supreme Court highlighted the essential elements of robbery with homicide. These elements include: (1) the taking of personal property with violence or intimidation against persons; (2) the property belongs to another; (3) the taking is done with animo lucrandi (intent to gain); and (4) homicide is committed by reason of or on the occasion of the robbery. The court determined that all elements were met in this case.

The accused raised the defense of alibi and denial. Orlando Dinamling testified that he was at home resting. Fernando Dinamling claimed he was at his house in Bimmangon, Quirino, Isabela. Both alibis were corroborated by family members. However, the Court found these defenses weak and insufficient to overcome the positive identification of the accused by the prosecution witnesses. According to prevailing jurisprudence, alibi is inherently weak and requires the accused to demonstrate the physical impossibility of their presence at the crime scene. Here, the Court noted the proximity between the accused’s residences and the Pajarillos’ house, making it feasible for the accused to be present at the time of the crime.

The Supreme Court addressed the contention that no evidence was adduced to prove the culpability of the accused for the victims’ deaths. The Court noted the chain of events: the accused ordering the victims to lie down, pointing guns at their heads, the sound of gunshots, and the discovery of the deceased with gunshot wounds. It said these events sufficiently linked the accused to the homicides. The Court clarified the offense’s designation, stating that despite the double homicide, the crime remains robbery with homicide, as the number of deaths does not increase the penalty. The Court affirmed the finding of conspiracy among the accused. The accused demonstrated unity of purpose, intent, and design to carry out the unlawful act.

The Supreme Court addressed the appropriate penalties and civil liabilities. The trial court correctly appreciated the presence of a band as an aggravating circumstance because more than three armed malefactors acted together in the commission of the offense. The Court ultimately upheld the death penalty, in line with Article 63 of the Revised Penal Code which provides that when the law prescribes a penalty composed of two indivisible penalties and there is only one aggravating circumstance, the greater penalty shall be applied. In terms of civil liabilities, the Court modified the award of damages to include restitution, indemnity for death, loss of earning capacity, moral damages, and exemplary damages, in line with existing jurisprudence.

FAQs

What was the main crime the accused were convicted of?	The accused were convicted of Robbery with Homicide, a special complex crime under Philippine law. This means they were found guilty of committing robbery that resulted in the death of individuals.
What evidence led to the accused being identified as the perpetrators?	Positive identification by eyewitnesses, particularly the victims of the robbery, played a crucial role. The court emphasized that victims often remember the faces of their attackers, making their testimony reliable.
What is the significance of “animo lucrandi” in this case?	“Animo lucrandi” refers to the intent to gain or profit. The prosecution proved that the accused had the intention to steal property during the robbery, which is an essential element of the crime.
How did the court address the defense of alibi presented by the accused?	The court found the alibi weak because the accused failed to prove it was physically impossible for them to be at the crime scene. Their residences were near the location where the crime occurred.
Why was the aggravating circumstance of a “band” considered?	The aggravating circumstance of a “band” was considered because more than three armed individuals participated in the commission of the crime. This element increased the severity of the offense.
What is the legal basis for holding all participants responsible for the resulting homicide?	Under Philippine law, if homicide results from a robbery, all those who participated as principals in the robbery are also held guilty as principals of robbery with homicide. Unless they actively tried to prevent the homicide.
What types of damages were awarded to the victims’ families?	The victims’ families were awarded various damages, including death indemnity, compensation for loss of earning capacity, funeral and burial expenses, moral damages, and exemplary damages.
How does this case define the relationship between robbery and homicide?	The case reinforces the principle that when a homicide occurs by reason of or on the occasion of a robbery, the composite crime of robbery with homicide is committed. The number of deaths does not change the nature of the crime, but it can affect the penalty.

The Supreme Court’s decision in People vs. Dinamling underscores the gravity of robbery with homicide and reiterates the importance of eyewitness testimony, the weakness of alibi as a defense when not adequately supported, and the collective responsibility of participants in a robbery that results in death. The decision provides a framework for understanding the elements of the crime, the assessment of evidence, and the determination of appropriate penalties and civil liabilities in similar cases.

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 vs. Dinamling, G.R. No. 134605, March 12, 2002