## FACTS:

The criminal cases involved Paulino Pat and Raul Sandoval who were charged with robbery with homicide and highway robbery. The incidents occurred in Cebu City on May 31, 1986, at around 1:30 in the early morning. A group of young men, including Franklin Baguio, Romeo Laurente, and Amelito Undalok, decided to spend the night at the house of Nemesio Dakay after attending an amateur singing contest. Undalok noticed Sandoval and Pat following them from a distance. Sandoval and Pat overtook them and proceeded to rob and frisk Laurente and Baguio. Baguio resisted giving his wallet when Sandoval stabbed him in the chest. Baguio died due to severe hemorrhage from the stab wounds. Undalok identified Sandoval and Pat to the police, leading to the filing of criminal cases against them for robbery with homicide and violation of Presidential Decree No. 532. The defense claimed that another person or group committed the crimes, but witnesses and evidence supported the prosecution's version of events.

On May 31, 1986, Enrique Restauro, a barangay tanod, witnessed a person being stabbed while conducting a roving patrol. He described the assailant as having a "flat nose and high cheekbones," and heard from others that a person named Roland Sobrevilla was known to be violent. Virgilio Nacion, a driver-mechanic, also witnessed the stabbing and saw the two assailants run away. He declined to give one of the assailants a ride in his cab as it was still not functioning. Nacion also heard from people in the area that Roland was the culprit. Wifredo Gonzaga testified that he knew the accused, Pat and Sandoval, and knew their whereabouts during the time the crimes were committed.

The defense presented Manuel Gatis, the father of Wilfredo Gatis, who was known by various aliases and had a criminal history. Manuel testified that Wilfredo arrived at their home with two companions on the morning of May 31, 1986. He overheard Wilfredo admitting to killing a person who refused to surrender his watch and wallet. However, Wilfredo himself was killed in a shootout with the police in 1989. Bruno Zafra, a former chief investigator, testified that a homosexual being investigated implicated Roland and two unidentified persons as the suspects in the crimes.

To support their alibis, the accused, Sandoval and Pat, testified that they were sleeping together in Pat's store on the evening of May 31, 1986, and denied their involvement in the crimes. Sandoval admitted knowing about the crimes and being investigated by the police but denied being identified as the person responsible. Pat confirmed the same address as Sandoval and claimed to have been in his store from May 30 to June 5, 1986.

On May 18, 1990, the trial court found Sandoval and Pat guilty of robbery with homicide in Criminal Case No. CBU-8728. The accused, Raul Sandoval and Paulino Pat, were convicted of the crimes of Robbery with Homicide and Highway Robbery. In Criminal Case No. CBU-8731, they were found guilty beyond reasonable doubt of the crime of Robbery with Homicide and sentenced to reclusion perpetua. They were also ordered to indemnify the heirs of the deceased Franklin Baguio in the amount of P30,000.00 and to pay the costs. In Criminal Case No. CBU-8732, they were found guilty beyond reasonable doubt of the crime of Highway Robbery and sentenced to imprisonment for a period of Twelve (12) Years and One (1) Day to Twelve (12) Years, Ten (10) Months, and Twenty (20) Days. They were also ordered to pay the costs. The two accused filed a common notice of appeal. On June 6, 1989, Pat was released from detention after posting a cash bond. Sandoval's counsel filed a manifestation and motion stating that they were availing of the provision of the new Rules on Criminal Procedure, which allows the original bail bond to be considered as such until the final determination of the case, and requesting favorable action on the manifestation.

ISSUES

1. Whether the accused should have been charged only with the complex crime of robbery with homicide instead of both robbery with homicide and highway robbery.

2. Whether the identification of the accused was reliable and sufficient for conviction.

3. Whether the accused should be acquitted due to reasonable doubt considering their contention of being employed and thus unlikely to commit the crimes.

RULING

1. The Supreme Court clarified that separate charges of robbery with homicide and highway robbery were appropriate given that the offenses were committed against two different victims under distinct provisions of the law. However, the Court found the charge under PD No. 532 (highway robbery) inappropriate, adjusting it to simple robbery as defined under the Revised Penal Code, based on the factual allegations.

2. The identification of the accused by the eyewitness was deemed credible and reliable by the trial court, which was affirmed by the Supreme Court. This decision was based largely on the detailed and consistent testimony provided by the eyewitness despite rigorous cross-examination and the lack of evidence of any improper motive.

3. The Supreme Court rejected the argument for acquittal based on the accused's employment status, affirming the lower court's finding of guilt. The Court reiterated that motive is not indispensable to conviction where there is positive identification of the accused. Concerning the charges, the Court modified the trial court's decision, holding the accused guilty of attempted robbery with homicide in one case and simple robbery in the other, applying appropriate penalties for each.

PRINCIPLES

1. Multiplicity of Charges: An accused can be charged with multiple offenses arising from the same act if each offense involves distinct and unrelated provisions of the law.

2. Credibility of Eyewitnesses: The credibility of eyewitness testimony is generally upheld by appellate courts, especially when affirmed as reliable by the trial court and when there is no evidence of any ulterior motive to lie.

3. Interpretation of Charges and Statutes: In interpreting criminal charges, the factual allegations rather than the statutory designation of the crime are controlling. Statutory interpretation should avoid absurd results, focusing on legislative intent.

4. Liability Under Conspiracy in Special Complex Crimes: In crimes like robbery with homicide, all participants in the robbery can be held liable for resultant homicide if committed on the occasion of robbery, unless there is clear evidence that they attempted to prevent the killing.

5. Proof Beyond Reasonable Doubt and Role of Motive: While motive aids in understanding why an offense might have been committed, it is not essential for conviction if the accused's guilt is established beyond reasonable doubt through clear and convincing evidence.