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PEOPLE v. VIVENCIO LABUGUEN

FACTS:

The case involves an automatic review of the decision of the RTC of Cauayan, Isabela, finding the appellant Vivencio Labuguen guilty of Robbery with Homicide. The information alleges that on October 27, 1994, Labuguen took cash amounting to P40,000 belonging to Bonifacio Angeles by means of force, violence, and intimidation. It further alleges that Labuguen assaulted and shot Bonifacio several times with a firearm and stabbed him several times with a pointed/bladed instrument, causing his death.

The trial court summarized the pertinent facts as follows: Bonifacio Angeles, a businessman engaged in buying cows, lived with Marilou Dabo. On the day of the incident, Tomas Pagbigayan saw Labuguen riding on a motorcycle driven by Bonifacio. Tomas recognized Labuguen because he saw him talking to Romy Bariza days before. Labuguen was wearing sunglasses and a handkerchief tied around his forehead.

Later that morning, Pantaleon Tagora encountered Labuguen and another person while walking near an irrigation canal. Tagora described Labuguen as a young person wearing a yellow jacket with a round face and not wearing sunglasses or a headband. Elpidio Rivera, another farmer, saw Labuguen riding on a red motorcycle near his house. He identified Labuguen in court, mentioning that he was wearing a light yellow jacket and had a handkerchief tied around his forehead.

Around 11:00 to 12:00 noon, Geronimo Rivera, a mini-bus driver, saw a person behind some grass near the National Highway. The person had blood stains on his clothes and was wearing a cream jacket, maong pants, sunglasses, and a handkerchief tied around his forehead. The person flagged down the bus and sat alone on the 5th-row seat.

ISSUES:

  1. Whether the trial court erred in convicting the accused based on circumstantial evidence.

  2. Whether the trial court erred in disregarding the evidence presented by the defense.

  3. Whether the trial court erred in finding the accused guilty beyond reasonable doubt.

  4. Whether the circumstantial evidence presented by the prosecution is sufficient to establish the guilt of the appellant beyond reasonable doubt.

  5. Whether or not the appellant established the requisite physical impossibility of his presence at the scene of the crime.

  6. Whether or not the defense of alibi can prevail over the positive identification by prosecution witnesses.

  7. Whether or not the generic aggravating circumstances of fraud and craft were properly appreciated.

RULING:

  1. The trial court did not err in convicting the accused based on circumstantial evidence. Circumstantial evidence is sufficient for conviction if there is more than one circumstance, the facts from which the inferences are derived are proven, and the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt. In this case, the testimonies of the prosecution witnesses established a chain of events that led to the inevitable conclusion that the accused was the guilty person.

  2. The trial court did not err in disregarding the evidence presented by the defense. The defense's theory of denial and alibi was vehemently denied by the accused. However, the testimonies and evidence presented by the prosecution established the accused's presence at the scene of the crime, linking him directly to the commission of the offense.

  3. The trial court did not err in finding the accused guilty beyond reasonable doubt. The combination of circumstantial evidence and the testimony of the prosecution witnesses established the accused's guilt and excluded the possibility of any other person being responsible for the crime. The prosecution successfully proved the elements of the offense charged, and the trial court correctly applied the rules on evidence to arrive at a conviction.

  4. The Court held that the circumstantial evidence presented by the prosecution is sufficient to establish the guilt of the appellant beyond reasonable doubt. The unbroken chain of events, supported by witness testimonies and physical evidence, directly link the appellant to the crime. The time element of the circumstances shows that the appellant was the last person seen with the victim before the latter was killed, and was later seen fleeing the crime scene with blood on his clothes and a large sum of money in his possession. These circumstances, coupled with the fact that appellant was identified as the person last seen with the victim, serve as strong evidence of his guilt. The Court affirmed the conviction of the appellant for the crime of robbery with homicide.

  5. The appellant failed to establish the requisite physical impossibility of his presence at the locus criminis at the approximate time of its commission. Therefore, this defense cannot be relied upon by the appellant.

  6. The defense of alibi cannot prevail over the positive identification by the prosecution witnesses.

  7. The trial court properly appreciated the generic aggravating circumstances of fraud and craft.

PRINCIPLES:

  • Circumstantial evidence can be sufficient for conviction if it constitutes an unbroken chain leading to one fair reasonable conclusion pointing to the accused as the guilty person, to the exclusion of all others. (Section 4, Rule 134 of the Rules on Evidence)

  • The trial court has the discretion to evaluate the credibility of witnesses and weigh the evidence presented. If the trial court's findings are supported by substantial evidence, they are entitled to great weight and will not be disturbed on appeal.

  • Circumstantial evidence can be sufficient to establish guilt beyond reasonable doubt.

  • The time element of the circumstances can be used to link each chain of events and establish the guilt of the accused.

  • Robbery can be inferred as the motive for a crime based on the attendant circumstances.

  • The credibility of witnesses is generally upheld by appellate courts, as the trial court has the opportunity to observe their demeanor and manner of testifying.

  • Alibi can only prosper if the accused proves that it was physically impossible for them to be at the crime scene when the crime was committed.

  • In order to establish the defense of alibi, the accused must prove that he was somewhere else when the crime was committed and it was physically impossible for him to have been at the scene of the crime.

  • The defense of alibi cannot prevail over positive identification by the prosecution witnesses.

  • Craft involves intellectual trickery and cunning on the part of the offender, while fraud is present when there is a direct inducement by insidious words or machinations.

  • The penalty for Robbery with Homicide under Article 294 of the Revised Penal Code is reclusion perpetua to death. The presence of aggravating circumstances and the absence of mitigating circumstances can result in the imposition of the maximum penalty.

  • Republic Act No. 7659, which prescribes the death penalty, is constitutional and the penalty prescribed under it must be imposed.