Case Digest (G.R. No. 127841)
Facts:
People of the Philippines v. Epie Arlalejo y Capucanan, G.R. No. 127841, June 16, 2000, the Supreme Court En Banc, Puno, J., writing for the Court.
The criminal information charged Epie Arlalejo y Capucanan, Jerry Albasin, and an unidentified “Junior Doe” with robbery with homicide under Article 294 of the Revised Penal Code (as amended) for the killing of Simplicio Manongas during a nighttime robbery at the home of spouses Emiliano and Bernardita Manongas in Sitio Sihagan, Barangay Uba, Cortes, Surigao del Sur on February 12, 1995. The Information alleged a conspiracy among the accused, the taking of P700.00, and that Simplicio was stabbed to death; damages and the imposition of death under Republic Act No. 7659 were prayed for.
At arraignment the two named accused pleaded not guilty and trial followed. The spouses testified that a man (identified as Jerry Albasin) called for a light; when Emiliano opened the door two men (later alleged to be the appellant and Junior Doe) forced entry, overpowered Emiliano and Bernardita, blew out the lamp, demanded money and took P700.00; the robbers saw Simplicio on the porch on their way out, took him, and the spouses later saw through a window that he was being stabbed. Police found Simplicio dead the next morning with multiple stab wounds. The Manongas spouses did not immediately name the suspects that same night.
Both appellant Arlalejo and co-accused Albasin raised alibi defenses and presented witnesses who testified they were together at betamax showings and at homes from about 7:00 p.m. to 10:00–11:00 p.m. Appellant also assisted in preparing Simplicio’s body for burial the next day. Two days after burial appellant was arrested; Efren Paquez, accompanied by the Manongas, later identified him as one of the robbers. The trial court noted the acquittal of Albasin on reasonable-doubt grounds but convicted appellant Arlalejo of robbery with homicide, sentenced him to death, awarded indemnity and damages, and ordered that the case record be sent to the Supreme Court for automatic review (Decision of the Regional Trial Court, Branch 41, Cantilan, Surigao del Sur, dated November 8, 1996). Junior Doe remained at large.
Appellant raised two principal assignments of error to the Supreme Court: (1) that conspiracy was not proved so that the inconsistent outcome (acquittal of Albasin but co...(Subscriber-Only)
Issues:
- Does the acquittal of a supposed co-conspirator (Jerry Albasin) require the acquittal of appellant Epie Arlalejo on the ground that conspiracy was not proved?
- Did the prosecution prove appellant’s identity as one of the robbers beyond reasonable doubt where the victims failed to identify him immediately and there was an unexplai...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)