PEOPLE v. DANILO CORBES Y OLAZO

FACTS:

On November 17, 1990, six armed men entered the premises of the Caloocan Consortium Corporation and robbed the establishment of cash amounting to P169,000.00 and P4,500.00 from an employee named Mateo Figuracion. They also shot and killed security guard Timoteo Palicpic and took his .38 caliber revolver. The robbers then fled towards 8th Avenue where Danilo Corbes and Manuel Vergel had parked their getaway vehicle, a blue passenger jeep. Corbes and Vergel then sped away.

Later that day, Vergel went to the Caloocan Police Station and reported the incident. He initially claimed that the robbers used his passenger jeep without his knowledge or participation in the robbery. However, upon further interrogation, he pointed to Corbes as the one who planned the robbery and convinced him to drive for them. Corbes, on the other hand, identified a certain "Benny" as the mastermind.

Corbes, Vergel, and six other individuals who are still at large were charged as principals by conspiracy. During the trial, Vergel diverged from his earlier statement and insisted that he was merely hired by Corbes and Benny to drive the jeep. He claimed that he only became aware of the robbery when Benny returned from Cordero Street with armed men who forced him to drive the jeep. Corbes also maintained his innocence and stated that he only accompanied Benny and Vergel to look for a jeep for hire.

The trial court convicted Corbes and Vergel based on the eyewitness account of Elena San Jose, who saw the two accused participating in the robbery as a lookout and driver, respectively. San Jose testified that she saw Vergel alight from the jeep several times to inspect its engine, while Corbes walked along 8th Avenue. Later on, four men approached the jeep and boarded it before it drove away.

In addition, Dante Despida, the owner of the Gulf-Pacific Security Agency, Inc., testified that on November 19, 1990, Vergel and Corbes admitted to him inside the Caloocan Police Station that they participated in the robbery as the driver of the getaway vehicle and lookout, respectively. Vergel and Corbes were then sentenced to reclusion perpetua and ordered to pay damages to the heirs of Timoteo Palicpic.

ISSUES:

  1. Whether the appellants' presence at the crime scene is enough to prove conspiracy.

  2. Whether the testimony of Elena San Jose is credible.

RULING:

  1. The Supreme Court ruled that the appellants' presence at the crime scene is sufficient to establish conspiracy. The evidence showed that Corbes acted as the lookout while Vergel was the driver of the getaway vehicle. Their actions demonstrated a pre-arranged plan and coordination with the other perpetrators, thereby proving their conspiracy beyond reasonable doubt.

  2. The Supreme Court upheld the credibility of Elena San Jose's testimony. Her eyewitness account provided critical details regarding the appellants' participation in the robbery. The alleged inconsistencies in her testimony were minor and did not affect the overall trustworthiness of her account.

PRINCIPLES:

  • Conspiracy may be inferred from the acts and conduct of the accused, including their presence at the crime scene, as long as there is coordination and a pre-arranged plan.

  • Eyewitness testimony, if credible and reliable, can be sufficient to establish the guilt of the accused. Minor inconsistencies or discrepancies in the testimony do not necessarily affect its overall credibility.