GR 130656; (June, 2000) (Digest)
G.R. No. 130656 ; June 29, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARMANDO REANZARES also known as ARMANDO RIANZARES, accused-appellant.
FACTS
Spouses Gregorio and Lilia Tactacan were traveling home by jeepney on May 10, 1994, when two men boarded. After a short distance, they, along with two accomplices waiting ahead, hijacked the vehicle. Gregorio was restrained, blindfolded, and robbed. During the ordeal, Lilia pleaded for mercy. A commotion ensued, and she was heard crying out in pain. The perpetrators fled, and Gregorio later found his wife dead inside the jeep from multiple stab wounds. Cash and a wristwatch were stolen.
Accused Armando Reanzares was identified by Gregorio as one of the waiting accomplices who approached the vehicle and later drove it. Reanzares presented an alibi, claiming he was in Camarines Sur for his daughter’s baptism. His father and brother corroborated his travel but could not confirm his actual presence at the destination. The trial court convicted him of Highway Robbery with Homicide under P.D. No. 532 and imposed the death penalty, but acquitted him of carnapping.
ISSUE
Whether the conviction of accused-appellant Armando Reanzares for Highway Robbery with Homicide is proper.
RULING
The Supreme Court affirmed the conviction but modified the crime and penalty. The Court held that the prosecution proved Reanzares’s guilt beyond reasonable doubt. Gregorio’s positive identification, made under sufficient opportunity to observe the accused during the well-lit crime, prevails over the weak alibi, which was not physically impossible. The defense witnesses failed to conclusively prove Reanzares was in Camarines Sur at the exact time of the crime.
However, the Court reclassified the offense. P.D. No. 532 requires the robbery to occur on a “highway,” defined as a public thoroughfare. The evidence showed the initial robbery of Gregorio’s watch occurred inside the jeepney, which was parked off the highway at the time. The subsequent taking of cash from Lilia, though on the highway, was part of a continuous series of acts. Since not all elements of robbery occurred on the highway itself, the proper crime is Robbery with Homicide under Article 294 of the Revised Penal Code. The penalty is reclusion perpetua, as the qualifying circumstance of the offense occurring on a highway was not proven. The Court also modified the awarded damages, increasing moral damages and loss of earning capacity, while reducing unsubstantiated expenses.