G.R. No. 212932 - PEOPLE OF THE PHILIPPINES, VS. ARNEL BALUTE Y VILLANUEVA, ACCUSED-.R E S O L U T I O N - Supreme Court E-Library

Ruling

accordingly, sentenced him to suffer the penalty of reclusion perpetua , without eligibility for parole, in lieu of the death penalty, as well as ordered him to pay the heirs of SPO1 Manaois the amounts of P50,000.00 as civil indemnity, P6,000.00 as compensatory damages for the value of the stolen mobile phone, and P50,000.00 as moral damages, with interest at the rate of six percent (6%) per annum (p.a.) from the filing of the Information. [9] It found that the prosecution was able to establish the existence of all the elements of Robbery with Homicide, as it proved that Balute poked his gun at SPO1 Manaoiss side, took his mobile phone, and shot him, resulting in the latters death. In this relation, the RTC gave credence to Cristita and Blesildas positive identification of Balute as the assailant, as compared to the latters mere denial and alibi. [10] Aggrieved, Balute appealed to the CA. The CA Ruling In a Decision [11] dated February 3, 2014, the CA affirmed Balutes conviction with modification in that: ( a ) the aggravating circumstance of treachery was no longer considered as the prosecution failed to allege the same in the Information; [12] ( b ) the civil indemnity was increased to P75,000.00 in view of existing jurisprudence;(c) the P6,000.00 compensatory damages, representing the value of the mobile phone, was deleted in the absence of competent proof of its value, and in lieu thereof, actual damages in the aggregate amount of P140,413.53 representing SPO1 Manaoiss hospital and funeral expenses was awarded to his heirs; and (d) all the monetary awards for damages are with interest at the rate of six percent (6%) p.a. from the date of finality of the CA Decision until fully paid. [13] Hence, the instant appeal. The Issue Before the Court The lone issue for the Courts resolution is whether or not the CA correctly upheld Balutes conviction for Robbery with Homicide. The Courts Ruling The appeal is bereft of merit. It must be stressed that in criminal cases, factual findings of the trial court are generally accorded great weight and respect on appeal, especially when such findings are supported by substantial evidence on record. It is only in exceptional circumstances, such as when the trial court overlooked material and relevant matters, that the Court will re-calibrate and evaluate the factual findings of the court below. [14] Guided by the foregoing principle, the Court finds no cogent reason to disturb the RTCs factual findings, as affirmed by the CA. In People v. Ibañez , [15] the Court exhaustively explained that [a] special complex crime of robbery with homicide takes place when a homicide is committed either by reason, or on the occasion, of the robbery. To sustain a conviction for robbery with homicide, the prosecution must prove the following elements: (1) the taking of personal property belonging to another; (2) with intent to gain; (3) with the use of violence or intimidation against a person; and (4) on the occasion o