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PEOPLE v. NGANO SUGAN

FACTS:

The case involves an appeal from the decision of the Court of Appeals affirming the conviction of appellants Gaga Latam, Saligo Kuyan, and Kamison Akoy for the crime of robbery with homicide. The armed appellants, along with their companions, entered Fortunato Delos Reyes' house and declared a hold-up. They ordered the occupants to drop to the floor and inquired about the money and other valuables. The appellants took cash, personal belongings, and an air gun. One of the appellants, Ngano Sugan, then shot and killed Nestor Delos Reyes. Reggie Delos Reyes, another son of Fortunato and Thelma, arrived at the scene and was prevented from entering the house by Kamison and Cosme Latam. The appellants and their companions fled together. The appellants were charged with robbery with homicide, and after trial, the Regional Trial Court found them guilty and imposed the penalty of reclusion perpetua. The Court of Appeals affirmed the decision, finding that the appellants acted in conspiracy. The Supreme Court denied the appeal and affirmed the conviction, but modified the designation of the offense and the amounts of the awarded indemnities. The Court found that the appellants were guilty of robbery with homicide and ordered them to pay moral damages, temperate damages, and exemplary damages to the victim's heirs.

ISSUES:

  1. Whether the appellants are guilty beyond reasonable doubt of robbery with homicide.

  2. Whether the appellants acted in conspiracy in committing the crime.

  3. Whether the defenses of denial and alibi raised by the appellants have merit.

  4. Whether the lower courts correctly imposed the penalty of reclusion perpetua on the appellants.

  5. Whether additional damages should be awarded to the victim's heirs.

RULING:

  1. The appellants are found guilty beyond reasonable doubt of the crime of robbery with homicide.

  2. The appellants acted in conspiracy in committing the crime.

  3. The defenses of denial and alibi raised by the appellants do not have merit.

  4. The lower courts correctly imposed the penalty of reclusion perpetua on the appellants.

  5. Additional damages should be awarded to the victim's heirs.

PRINCIPLES:

  • Robbery with homicide requires the elements of taking personal property with intent to gain, use of violence or intimidation against a person, and the killing being on the occasion or by reason of the robbery.

  • All those who took part as principals in the robbery will be held guilty as principals of robbery with homicide, unless they sought to prevent the killing.

  • Conspiracy may be inferred from the acts of the accused that indicate a joint purpose, concert of action, and community of interest.

  • Denial is a negative, self-serving evidence that cannot prevail over positive identification.

  • Alibi is generally viewed with suspicion and is considered weak and unreliable.

  • The penalty for robbery with homicide is reclusion perpetua to death, but with the prohibition of the death penalty, the imposable penalty is reclusion perpetua.

  • The presence of an aggravating circumstance justifies the imposition of exemplary damages.