In the case of People v. Mancao, the Supreme Court affirmed the conviction of the accused for robbery with homicide, emphasizing that even without direct evidence, circumstantial evidence can sufficiently establish guilt. This ruling underscores that when a robbery results in a death, the accused can be convicted of robbery with homicide if the circumstances clearly link them to both crimes. This decision serves as a reminder that the prosecution can rely on a chain of events to prove guilt beyond a reasonable doubt, especially when direct evidence is lacking, ensuring that perpetrators of heinous crimes do not evade justice due to evidentiary gaps.

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

The case revolves around the death of Peter Ray Garcia Enriquez, who was allegedly robbed and killed by Jay Godoy Mancao. The prosecution presented evidence indicating that Mancao stabbed Enriquez, took his belongings, and attempted to conceal the crime. The key issue before the Supreme Court was whether the circumstantial evidence presented by the prosecution was sufficient to prove beyond a reasonable doubt that Mancao committed robbery with homicide, especially in the absence of direct eyewitness testimony to the actual taking of the victim’s belongings. This case highlights the importance of circumstantial evidence in criminal proceedings.

The Revised Penal Code’s Article 294(1) defines robbery with homicide, prescribing penalties ranging from reclusion perpetua to death when a homicide occurs by reason or on the occasion of a robbery. The elements of this crime, as established in jurisprudence, require that: (1) personal property is taken with violence or intimidation; (2) the property belongs to another; (3) the taking is with animo lucrandi (intent to gain); and (4) homicide is committed by reason or on the occasion of the robbery. The Supreme Court has consistently held that the robbery must be the primary objective, with the killing merely incidental.

In this case, the prosecution did not present direct evidence of the actual taking of the victim’s personal property. Instead, it relied on circumstantial evidence. One crucial piece of evidence was the testimony of Manuel Bernido, Jr., who witnessed Mancao stabbing Enriquez. Bernido’s testimony established the act of violence against the victim. Furthermore, SPO2 Kelvin Magno testified that a silver necklace belonging to the victim was found in Mancao’s possession upon his arrest. Pedro Enriquez, the victim’s father, identified this necklace as the one he had gifted to his son.

The Supreme Court referenced People v. Beriber, emphasizing that a conviction can be sustained even without direct testimony if the incriminating circumstances form an unbroken chain leading to the conclusion that the accused is responsible for the crime. The court applied Section 3(j), Rule 131 of the Rules of Court, which states that a person found in possession of a thing taken in the doing of a recent wrongful act is presumed to be the taker and the doer of the whole act. Mancao failed to provide a credible explanation for his possession of the victim’s necklace, leading to the presumption that he stole it and was the perpetrator of the crime.

The element of animus lucrandi, or intent to gain, was also inferred from Mancao’s unlawful possession of the victim’s necklace. Intent to gain is an internal act that is presumed from the unlawful taking of the property. Since the necklace was recovered from Mancao, the court presumed his intent to gain. Eyewitness Manuel Bernido, Jr.’s testimony further solidified the prosecution’s case, recounting how Mancao stabbed the victim. This testimony established the element of homicide. Bernido’s account, combined with the discovery of the victim’s necklace in Mancao’s possession, created a compelling narrative of robbery with homicide.

The defense presented by Mancao consisted of denial and alibi, claiming he was tending to his mother’s land in Compostela Valley at the time of the crime. The Supreme Court has consistently held that denial and alibi are inherently weak defenses because they can be easily fabricated. Such defenses cannot prevail over the credible and categorical testimonies of prosecution witnesses. The Court deferred to the trial court’s evaluation of the credibility of the witnesses, noting that the trial court had the unique opportunity to observe their demeanor and conduct during examination.

The Supreme Court emphasized that the incident’s timing, around 3:30 a.m., did not preclude Bernido, Jr. from clearly recognizing Mancao as the assailant. Bernido, Jr. was only about ten meters away when he witnessed the stabbing. Moreover, Mancao passed by Bernido’s house twice after the incident, even engaging in a brief conversation where Bernido questioned the blood stains on Mancao’s shirt. These multiple encounters provided ample opportunity for Bernido to ascertain Mancao’s identity, reinforcing the accuracy of his identification during the trial.

The Court highlighted the unbroken chain of events: Bernido’s eyewitness account of the stabbing, the recovery of the victim’s necklace from Mancao’s possession, and the victim’s father’s confirmation that the necklace belonged to his son. These circumstances led to the conclusion that Mancao’s primary intent was to rob the victim, and the killing was merely a means to facilitate the robbery. The absence of any prior relationship or conflict between Mancao and the victim further supported the conclusion that the killing occurred solely by reason or on the occasion of the robbery.

In affirming the conviction, the Supreme Court also addressed the appropriate penalties and monetary awards. The Court sustained the imposition of reclusion perpetua, given the absence of any mitigating or aggravating circumstances. Additionally, the Court upheld the awards of P75,000.00 as civil indemnity and P75,000.00 as moral damages. In line with prevailing jurisprudence, the Court further awarded P75,000.00 as exemplary damages and P50,000.00 as temperate damages. These amounts are subject to an interest rate of six (6) percent per annum from the finality of the judgment until fully paid.

FAQs

What is robbery with homicide?	Robbery with homicide is a crime under Article 294(1) of the Revised Penal Code, where a person commits robbery and, by reason or on occasion of the robbery, homicide occurs. The robbery must be the primary intent, with the killing being incidental.
Can a person be convicted of robbery with homicide based on circumstantial evidence alone?	Yes, a person can be convicted based on circumstantial evidence if the evidence forms an unbroken chain leading to the conclusion that the accused committed the crime. The circumstances must be more than one, and the facts from which the inferences are derived must be proven.
What is animus lucrandi?	Animus lucrandi is the intent to gain or profit from the taking of personal property. In robbery cases, this intent is a crucial element and is often presumed from the unlawful taking of property.
What is the significance of possessing stolen items in a robbery case?	Under Section 3(j), Rule 131 of the Rules of Court, a person found in possession of items taken during a recent wrongful act is presumed to be the taker and the doer of the whole act. This presumption can be used as evidence to link the person to the crime.
What are the penalties for robbery with homicide?	The penalty for robbery with homicide ranges from reclusion perpetua to death, depending on the circumstances of the crime. The court also typically orders the accused to pay civil indemnity, moral damages, exemplary damages, and temperate damages to the victim’s heirs.
Why are denial and alibi considered weak defenses?	Denial and alibi are considered weak defenses because they are easily fabricated. To be credible, an alibi must show that the accused was in another place for such a period of time that it was impossible for them to have been at the scene of the crime.
What is the role of eyewitness testimony in robbery with homicide cases?	Eyewitness testimony can provide direct evidence of the crime, but even without it, circumstantial evidence can be sufficient for conviction. The credibility of eyewitnesses is evaluated by the trial court, which has the opportunity to observe their demeanor and conduct.
What kind of monetary awards are typically granted in robbery with homicide cases?	Monetary awards in robbery with homicide cases typically include civil indemnity, moral damages, exemplary damages, and temperate damages. These awards aim to compensate the victim’s heirs for the loss and suffering caused by the crime.
How does the court determine the credibility of witnesses?	The court evaluates the credibility of witnesses based on their demeanor, conduct, and attitude during examination. The trial court’s findings on credibility are generally given great weight, especially when affirmed by the appellate court.

In conclusion, the Supreme Court’s decision in People v. Mancao reinforces the principle that circumstantial evidence, when strong and consistent, can be sufficient to prove guilt beyond a reasonable doubt in robbery with homicide cases. This ruling ensures that justice can be served even when direct evidence is lacking, protecting the rights of victims and upholding the integrity of the criminal justice system.

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. Mancao, G.R. No. 228951, July 17, 2019