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PEOPLE v. ROBERTO G. CAMPOS

FACTS:

Emeliza P. Empon was inside her house with her boyfriend Eric Sagun and neighbor Marilou Zafranco-Rea when an armed man suddenly barged into the house, took Emeliza's cellphone, and shot her in the chest, causing her death. Eric and Marilou reported the incident to the police station and described the suspect as "medyo malaki katawan." The police officers received information that the suspect was seen in Pasig City. They went to the target area, saw a man who matched the description, and arrested him. The man was identified as Roberto Campos. Eric and Marilou confirmed in a police lineup that Roberto was the one who robbed and killed Emeliza. Roberto was charged with the complex crime of Robbery with Homicide before the RTC, where he pleaded not guilty. The RTC convicted Roberto based on the positive identification of the eyewitnesses and rejected his alibi defense. Roberto appealed to the CA but his conviction was affirmed. He elevated the case to the Supreme Court, questioning the out-of-court identification and raising other issues. The appeal was deemed unmeritorious, and the totality of the circumstances showed that the eyewitnesses' out-of-court identification of Roberto was reliable and admissible.

ISSUES:

  1. Whether the identification made by the witnesses is reliable considering the conditions surrounding the identification process.

  2. Whether the time lapse between the commission of the crime and the out-of-court identification affected the accuracy of the identification.

  3. Whether the positive identification of the defendant by the witnesses is credible.

  4. Whether the positive identification of the accused by the witnesses is sufficient evidence of guilt in a robbery with homicide case.

  5. Whether the failure of the prosecution to present the result of the paraffin test is fatal to the case.

  6. Whether the accused's criminal liability for robbery with homicide is established based on the elements of the crime.

  7. Whether the penalty imposed by the trial court and affirmed by the Court of Appeals is correct.

  8. Whether the awards of damages are proper.

RULING:

  1. The Court finds that the identification made by the witnesses is reliable and credible. The Court considers several factors in reaching this conclusion. Firstly, the witnesses had a clear and unobstructed view of the perpetrator during the commission of the crime. Secondly, the description provided by the witnesses immediately after the crime matched the physique of the suspect during the lineup. Thirdly, there was only a short time lapse of seven hours between the crime and the out-of-court identification. Fourthly, the witnesses exhibited a high level of certainty in their identification of the defendant. Lastly, there is no evidence to suggest that the police officers influenced the witnesses' identification of the defendant.

  2. Yes, the positive identification of the accused by the witnesses is sufficient evidence of guilt in a robbery with homicide case. The Court of Appeals correctly held that the positive identification by the witnesses, who were certain that it was the accused who committed the crime, is a strong evidence of guilt. The fact that the accused did not present evidence to prove that he was somewhere else when the crime was committed further strengthens the identification made by the witnesses.

  3. No, the failure of the prosecution to present the result of the paraffin test is not fatal to the case. The Court ruled that the non-presentation of the paraffin test result is already irrelevant considering the positive identification of the accused by the witnesses. Moreover, the paraffin test is only a procedure to establish the presence or absence of nitrates or nitrites and is not indispensable in proving the guilt of the accused.

  4. Yes, the accused's criminal liability for robbery with homicide is established based on the elements of the crime. The Court explained that in a robbery with homicide case, the offender's original intent is to commit robbery and the homicide must only be incidental. The killing may occur before, during, or even after the robbery. In this case, all the elements of the special complex crime of robbery with homicide are present, as the accused took personal property with violence or intimidation against persons, the property taken belonged to another, the taking was done with intent to gain, and on the occasion of the robbery, homicide was committed.

  5. Yes, the penalty imposed by the trial court and affirmed by the Court of Appeals is correct. The crime of robbery with homicide carries the penalty of reclusion perpetua to death. In the absence of any aggravating circumstance, the trial court and the Court of Appeals appropriately imposed the penalty of reclusion perpetua in accordance with Article 63 of the Revised Penal Code.

  6. Yes, the awards of damages are proper. The Court affirmed the increase in the amounts of moral and exemplary damages to P75,000.00 each, in line with current jurisprudence. The Court also increased the award of temperate damages to P50,000.00 considering the absence of documentary evidence of burial or funeral expenses. Finally, the Court ordered the accused to either return the stolen item or pay its monetary value in the amount of P8,000.00 if restitution is no longer possible.

PRINCIPLES:

  • The accuracy of identification made by witnesses may be assessed based on various factors, including the conditions surrounding the identification process and the witnesses' level of certainty.

  • Discrepancies between prior descriptions and the actual appearance of the suspect do not necessarily invalidate the identification if there is no inconsistency.

  • The length of time between the crime and the identification is not determinative of its accuracy, and even identifications made a few days after the crime can be acceptable.

  • The credibility of witnesses' identification is given great respect and weight, especially if there is no basis to doubt their veracity and credibility.

  • Negative defenses such as denial and alibi are self-serving and require clear and convincing proof to prevail over positive identification.

  • Positive identification by credible witnesses is strong evidence of guilt.

  • Failure to present the result of a paraffin test is not fatal to a criminal case if there is positive identification by witnesses.

  • In a robbery with homicide case, the offender's original intent is to commit robbery and the homicide must only be incidental.

  • The consent or non-resistance of the victim does not negate the presence of violence or intimidation in a robbery with violence against persons.

  • The crime of robbery with homicide carries the penalty of reclusion perpetua to death.

  • The trial court has the discretion to award moral, exemplary, and temperate damages based on the circumstances of the case.