G.R. No. 270580 - People vs. Jose Roel Bragais y Sison and Alfredo Tacuyo y Evangelista

On or about July 14, 2011, in Caloocan City, Jose Roel Bragais y Sison (Bragais) and Alfredo Tacuyo y Evangelista (Tacuyo) were charged with the murder of Paula Apilado y Viray, a 12-year-old minor.
The Information alleged that the accused conspired to kill Paula by stabbing her multiple times, employing treachery, with evident premeditation and abuse of superior strength.
Bragais and Tacuyo pleaded not guilty upon arraignment.

Parties stipulated on the accused's employment as cemetery caretakers, the identities of the accused and Paula, Paula's minority, the autopsy report, and death certificate.

The prosecution presented witnesses including Alta Dela Cruz Delima (Alta), Mambo Dela Cruz Delima (Mambo) who has intellectual disability and speech impediment, Paula's relatives Lourdes Viray Bautista and August Raquel Bautista, and Dr. Robert Rey Sandiego.
Alta, Mambo's mother, testified about Mambo's intellectual disability with a mental age of 3 to 7 years per psychiatric evaluation but stated he was competent to testify.
Mambo testified as an eyewitness identifying the accused at the crime scene.

He recounted seeing the accused forcibly subdue Paula, tape her mouth, remove her clothing, stab her repeatedly, and sexually assault her with a broken bottle.
Mambo identified Tacuyo as "Totoy" and Bragais as "Roel."
He witnessed the accused drag Paula's body to a grassy area.
He was threatened by Tacuyo with a knife to not reveal what he saw.

Defense objected to leading questions posed to Mambo and requested documentary evidence of his mental age, which was later submitted through a Psychiatric Report.

Lourdes and August testified on the discovery of Paula's body in La Loma Cemetery, describing her condition as heavily bloodied with stab wounds.
Dr. Sandiego presented autopsy findings: Paula died from multiple stab wounds, and injuries suggested possible rape attempt.

Bragais denied involvement, knowledge of the victim and witnesses, raising alibis placing him at home and elsewhere during the timeline.
Tacuyo did not testify.

Found both accused guilty beyond reasonable doubt of murder.
Recognized Mambo as a competent and credible witness despite intellectual disability.
Imposed reclusion perpetua and ordered payment of civil indemnity, moral, and exemplary damages.

Affirmed conviction with modification on damages.
Upheld Mambo's competence and credibility, rejecting defense objections as waived for failure to timely object.
Held that inconsistencies in Mambo's testimony were not material; absence of hymenal injury did not negate murder charge.
Confirmed co-conspirator liability and the qualifying circumstance of treachery due to victim's minority.

Appeal filed by accused; issues raised included Mambo's competency, unreliability of testimony, absence of alleged treachery specifics.
Both parties adopted their Court of Appeals briefs.

Whether Mambo, a person with intellectual disability, is competent to testify as an eyewitness.
Whether inconsistencies in Mambo's testimony and lack of hymenal injury invalidate the prosecution's case.
Whether the absence of specific allegations of the means of treachery in the Information affects the qualification of murder.
Whether the accused's denial and alibi sufficiently rebut the prosecution's evidence.
Whether the elements of murder as provided under Article 248 of the Revised Penal Code are established.