Case Digest (G.R. No. L-3273)
Facts:
In People of the Philippines v. Rolly Adriano y Samson, G.R. No. 205228, decided July 15, 2015 under the 1987 Constitution, the accused-appellant Rolly Adriano y Samson (Appellant) was tried alongside co-accused Lean Adriano @ Denden, Abba Santiago y Adriano, John Doe, and Peter Doe for two separate killings that occurred on March 13, 2007 at around 8:00 a.m. on Olongapo-Gapan National Road, Barangay Malapit, San Isidro, Nueva Ecija. In Criminal Case No. 13159-07, Appellant stood charged with the homicide of bystander Ofelia Bulanan, who died from a stray bullet, while in Criminal Case No. 13160-07, he was charged with murder of Danilo Cabiedes, the driver of a maroon Honda CR-V. Trial evidence showed that Police Officer 1 Matthew Garabiles and PO2 Alejandro Santos, in civilian clothes, witnessed a blue Toyota Corolla (leased by Appellant) overtake the CR-V, discharge several shots resulting in Cabiedes’s death at Good Samaritan General Hospital and Bulanan’s immediate death atCase Digest (G.R. No. L-3273)
Facts:
- Procedural History
- Regional Trial Court (RTC) of Gapan City, Nueva Ecija, Branch 36, convicted Rolly Adriano y Samson for:
- Homicide (Crim. Case No. 13159-07) for the killing of Ofelia Bulanan.
- Murder (Crim. Case No. 13160-07) for the killing of Danilo Cabiedes.
- Court of Appeals (CA) in CA-G.R. CR-HC No. 04028 affirmed the RTC decision on 30 May 2011.
- The Supreme Court consolidated the appeal and promulgated its decision on 15 July 2015.
- Incident Description
- On March 13, 2007 at around 8 a.m. along Olongapo-Gapan National Road, Barangay Malapit, San Isidro, Nueva Ecija, a blue Toyota Corolla (plate WHK 635) overtook a maroon Honda CRV (plate CTL 957) occupied by Danilo Cabiedes.
- The front-seat passenger of the Corolla fired shots at the CRV, causing it to swerve into a canal. Four armed men then shot Cabiedes; a stray bullet struck bystander Ofelia Bulanan.
- Bulanan died on the spot (head wound); Cabiedes was pronounced dead on arrival at Good Samaritan General Hospital (three gunshot wounds to the chest).
- Investigation and Arrest
- The Corolla was registered to Antonio Y. Rivera, who admitted leasing it to Adriano. Police Officers 1 and 2, Matthew Garabiles and Alejandro Santos, positively identified Adriano as one of the assailants.
- Adriano was arrested later that day at Rivera’s shop; the PSOG headquarters recovered one deformed bullet and five .45-caliber cartridges.
- Defense alibi: Adriano claimed he was in Dolores, Magalang, Pampanga, washing clothes, fetching motorcycle repairs, visiting friends, and watching cockfights between 6 a.m. and 5 p.m.; corroborated by four relatives/friends.
Issues:
- Whether Adriano’s defense of alibi was sufficiently proven to create reasonable doubt.
- Whether minor inconsistencies in the testimonies of PO1 Garabiles and PO2 Santos undermine their positive identification of Adriano.
- Whether the killings constitute a complex crime or separate offenses, and whether qualifying circumstances were properly appreciated.
- Whether the computation and quantum of actual, moral, exemplary, and temperate damages awarded are correct.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)