In People v. Boquirin, the Supreme Court affirmed the conviction of Marcelo Boquirin for robbery with homicide, emphasizing the reliability of eyewitness testimony and upholding the principle that positive identification by a credible witness can outweigh the defense of denial. The Court underscored that when a robbery results in a killing, even unintentionally, the crime is classified as robbery with homicide, carrying a severe penalty. This ruling reinforces the importance of eyewitness accounts in criminal proceedings and clarifies the consequences of violence during robberies, ensuring justice for victims and their families.

Justice Delivered: How Eyewitness Testimony Convicted a Robber-Killer

The case revolves around the events of November 5, 1997, when Clarita Chua and her driver, Mario dela Cruz, were attacked while collecting payments. Chua was robbed at gunpoint, and Dela Cruz was fatally shot. Marcelo Boquirin was later identified by Chua as the shooter and one of the robbers. The trial court found Boquirin guilty of robbery with homicide, relying heavily on Chua’s eyewitness testimony.

At the heart of Boquirin’s appeal was the challenge to the credibility of Clarita Chua’s identification. He argued that the circumstances of the crime—a fleeting encounter during a robbery—made accurate identification impossible. He questioned whether Chua could have clearly seen him given the tinted windows of the van and the speed of the events. The Supreme Court, however, affirmed the trial court’s assessment, emphasizing the principle that matters of witness credibility are best judged by the trial court, which has the opportunity to observe the witness’s demeanor and assess their truthfulness. The Court reiterated that appellate courts should not interfere with these assessments unless there is a clear showing of overlooked material facts or grave abuse of discretion.

The Court highlighted several factors supporting the reliability of Chua’s identification. First, Chua positively identified Boquirin while he was detained at Camp Karingal and again in court. Second, she remembered him due to his face, clothes, and haircut. Third, the conditions of visibility were favorable, as the incident occurred during the day with bright sunlight, allowing her to clearly see the person on the other side of the van, even with tinted windows. The trial court specifically noted that Chua had every opportunity to see Boquirin’s face, further solidifying the credibility of her testimony.

The defense of denial presented by Boquirin was deemed weak in light of Chua’s positive identification. The Supreme Court has consistently held that a positive identification prevails over a denial, especially when the witness has no ulterior motive to falsely accuse the defendant. In this case, there was no evidence to suggest that Chua had any reason to lie or falsely implicate Boquirin, whom she had never met before the robbery. Her testimony was considered credible and reliable, forming a solid basis for the conviction. The Court stated, “Such positive testimony prevails over appellant’s denial of any participation in the robbery with homicide. As established at the trial, Clarita had no ulterior motive to falsely testify against appellant whom she has never met prior to the robbery. Her testimony is thus entitled to full faith and credit.”

Boquirin also alleged that the police at Camp Karingal exerted undue influence on Chua to identify him as the perpetrator. However, the Court found this allegation unsubstantiated, with no evidence on record to support the claim of undue influence. Furthermore, Chua’s immediate reaction after the robbery—reporting the incident to the police and providing a detailed description of the shooter—precluded the possibility of fabrication. This prompt and consistent account further bolstered the credibility of her identification.

The Court also addressed the issue of conspiracy in the commission of the offense. The evidence showed that Boquirin and two other individuals conspired to rob Chua. Boquirin shot and killed Dela Cruz while one of his companions stole Chua’s bag. The killing of Dela Cruz was directly related to the robbery, as it occurred during and because of the robbery. This established the complex crime of robbery with homicide, for which Boquirin and his accomplices are liable. According to Article 294 of the Revised Penal Code, as amended by Republic Act 7659:

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;

The trial court correctly imposed the sentence of reclusion perpetua on Boquirin, as there were neither aggravating nor mitigating circumstances. However, the Supreme Court modified the award of damages. The actual damages to Clarita Chua were reduced to P208,728, reflecting the specific amounts of cash, jewelry, and other items stolen. Additionally, the Court upheld the award of loss of earning capacity to the heirs of Mario dela Cruz, calculated at P640,000 based on his annual income and life expectancy. The Court explained the calculation as such:

X	= 2 (80-48) x [P60,000 – P30,000]
	3
	= 2 (32) x P30,000
	3
	=  64 x P30,000
	3
	=  P640,000

The Court also affirmed the award of P50,000 as civil indemnity for wrongful death and P50,000 as moral damages, consistent with prevailing jurisprudence. The decision underscores the principle that positive identification by a credible witness is sufficient to establish guilt beyond a reasonable doubt. It also clarifies the elements and penalties for the complex crime of robbery with homicide, providing a clear legal framework for similar cases.

FAQs

What was the key issue in this case?	The key issue was whether the eyewitness identification of the accused as the perpetrator of the robbery with homicide was credible and sufficient to prove his guilt beyond a reasonable doubt.
What is the crime of robbery with homicide?	Robbery with homicide is a complex crime where a robbery is committed, and on the occasion of or by reason of the robbery, a homicide (killing) occurs, regardless of whether the killing was intended. The penalty is typically more severe than simple robbery or homicide.
Why was the eyewitness testimony so important in this case?	The eyewitness testimony of Clarita Chua was crucial because she positively identified Marcelo Boquirin as the person who shot her driver and robbed her. Her detailed account and lack of ulterior motive made her testimony highly credible.
What factors did the Court consider when evaluating the credibility of the eyewitness?	The Court considered the witness’s opportunity to observe the perpetrator, the consistency of her statements, her demeanor in court, and the absence of any motive to falsely accuse the defendant. In this case, the conditions of visibility were also favorable.
What does reclusion perpetua mean?	Reclusion perpetua is a Philippine legal term for life imprisonment. It is a severe penalty imposed for serious crimes, such as robbery with homicide.
How is loss of earning capacity calculated in cases of wrongful death?	Loss of earning capacity is calculated by multiplying the victim’s life expectancy by their gross annual income minus living expenses. The formula is: Net Earning Capacity = (2/3) x (80 – Age) x (Gross Annual Income – Living Expenses).
What is civil indemnity?	Civil indemnity is a monetary compensation awarded to the heirs of a deceased victim in criminal cases. It is granted automatically upon conviction, without requiring proof of damages.
What are moral damages?	Moral damages are compensation for mental anguish, suffering, and similar injuries. They are awarded to allow the victim or their family to find solace for the emotional distress caused by the crime.
Can a person be convicted of robbery with homicide even if they didn’t directly kill the victim?	Yes, if the killing is directly connected to the robbery and occurs during the commission of the robbery, all participants in the robbery can be held liable for robbery with homicide, even if they did not personally commit the killing.

The Supreme Court’s decision in People v. Boquirin serves as a reminder of the weight given to credible eyewitness testimony and the severe consequences of committing robbery with violence resulting in death. This ruling underscores the judiciary’s commitment to ensuring justice for victims of violent crimes and upholding the rule of law.

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 v. Boquirin, G.R. No. 136829, June 6, 2002