RON DE GUZMAN DIMAAPI v. PEOPLE

FACTS:

This case originated from the filing of an Information before the Regional Trial Court (RTC) charging Ron De Guzman Dimaapi (Dimaapi), Jerry Supranes (Supranes), and an unidentified John Doe with the crime of robbery. The Information alleged that on September 19, 2010, in Barangay Dinahican, Infanta, Quezon, Dimaapi, Supranes, and John Doe, armed with a hammer, scissors, and other tools, conspired to forcibly enter the house and grocery store of Zenaida Angara (Angara). They allegedly destroyed the wall of the store, entered, and stole PHP 20,000.00 in cash and PHP 35,000.00 worth of cigarettes, totaling PHP 55,000.00. During the commission of the crime, Angara and her children were in a room inside the store, and Angara witnessed part of the incident.

Dimaapi pleaded not guilty upon arraignment on March 8, 2011, and Supranes did likewise after being apprehended nearly two years later. John Doe was not captured. The prosecution's narrative established that Lorena Atendido, a stay-in saleslady, informed Angara about a person inside the store, prompting Angara to seek help from her brother-in-law, Jerribel Madriaga. Upon arrival, Madriaga and barangay tanods climbed the roof, retrieved the store keys, and discovered Dimaapi hiding under boxes in the bodega. They found him in possession of various tools and a knife. Dimaapi later revealed his accomplices included Supranes.

The defense presented conflicting accounts, with Dimaapi claiming that he was invited into the store by Angara and was subsequently arrested without knowing the reason. Supranes provided an alibi, stating that he was at his home in a different barangay during the time of the incident.

The trial produced evidence that Angara's store doubled as her residence, and it was within these living quarters that the robbery occurred. Consequently, the lower courts convicted Dimaapi while acquitting Supranes on appeal due to reasonable doubt.

ISSUES:

  1. Whether the Court of Appeals correctly upheld Dimaapi's conviction for robbery in an inhabited house.

RULING:

The Supreme Court denied the petition and upheld the conviction of Ron De Guzman Dimaapi for robbery in an inhabited house as defined and penalized under Article 299 (a)(2) of the Revised Penal Code. The Court found that the circumstantial evidence presented was sufficient to prove beyond reasonable doubt that Dimaapi committed the crime. Accordingly, Dimaapi was sentenced to imprisonment for an indeterminate period of eight years and one day of prision mayor, as minimum, to 14 years, eight months, and one day of reclusion temporal, as maximum. He was also ordered to pay PHP 55,000.00 as actual damages with legal interest at the rate of 6% per annum from finality of this Decision until full payment.

PRINCIPLES:

  1. Circumstantial Evidence Circumstantial evidence is sufficient to support a conviction, and direct evidence is not always necessary. Circumstances must be consistent with each other, with the hypothesis of guilt, and inconsistent with any other hypothesis.

  2. Article 299 of the Revised Penal Code Defines and penalizes robbery in an inhabited house, including provisions for cases where entry is gained by breaking any wall, roof, or floor or breaking any door or window.

  3. Indeterminate Sentence Law The applicable penalty should be within the range provided by the law, considering the presence or absence of modifying circumstances.

  4. Civil Liability Ex Delicto Actual damages must be paid by the convicted party for the value stolen, with applicable legal interest as prescribed by law.