G.R. No. L-37642 - People vs. Casuga y Munar

On March 24, 2003, at approximately 4:45 p.m., a violent incident occurred at Monteverde Royal Subdivision in Taytay, Rizal during a small picnic involving Juliet Dumdum-Bimot and her boyfriend Virgilio “Jun” San Juan, Jr. y Molina.
Six assailants, one of whom was later identified as Ardo Bacero y Casabon (the accused-appellant), attacked the couple using deadly bladed weapons with the intent to rob.
During the assault, accused-appellant forcibly seized Jun’s cellphone after stabbing him in the face, while Juliet was physically overpowered by another companion of the accused.
Amid the chaos, Juliet’s attempts to defend herself were met with punches, and she experienced physical restraint, including being blindfolded with loosely tied towels that, however, enabled her to catch a glimpse of one attacker’s face.

Immediately following the incident, Juliet sought help from local security, and subsequently reported the matter to the police.
During her initial statement to Senior Police Officer 1 Rogelio V. Marundan at the Taytay Police Station, Juliet indicated that she recognized one of the attackers as having long hair—a feature associated with the accused-appellant whom she saw regularly near her residence.
Two days later, while accompanying investigating officers in a follow-up probe near Javier Compound, San Francisco Village, Muzon, Taytay, Juliet identified the accused-appellant standing in front of his house.
A police line-up was conducted where Juliet again positively identified Bacero; his subsequent admission, after initial denial, confirmed his involvement in the robbery and killing.

Juliet executed a supplemental affidavit two days after the incident to identify additional assailants, implicating other individuals such as Victor “Waray” Magcuro, Rommel David, Edwin Soberano y Dela Cruz, Nelson Ampatin, and Rodel Zacarias.
The defense presented an affidavit by Divina Esguerra Chiong asserting that she observed the incident from a neighboring vantage point and contended that the accused-appellant was not present, thus attempting to cast doubt on Juliet’s identification.
The prosecution supplemented Juliet’s testimony with additional evidence, including Estella Arellano San Juan’s testimony regarding the victim’s employment and the resulting damages and expenses.

The Regional Trial Court (RTC) of Antipolo City, Branch 73, found the accused-appellant guilty beyond reasonable doubt of the special complex crime of Robbery with Homicide under Article 294, paragraph (1) of the Revised Penal Code, as amended by Republic Act No. 7659.
The RTC’s decision was based primarily on Juliet’s immediate and consistent identification of the accused as the assailant who used a knife during the stabbing, and on the overall credibility of the eyewitness testimony.
The accused-appellant’s defenses centered on claims of mistaken identity, an alibi that he was at home gathering wood, and allegations that his confession was procured through police torture.
The Court of Appeals (CA) affirmed the RTC’s finding, albeit with modifications in the computation of damages, while emphasizing that the eyewitness identification and the totality of evidence supported the conviction.

The defense contended that Juliet’s identification was tainted by inconsistencies and that her earlier familiarity with the accused should have precluded such positive identification.
Accused-appellant claimed that his extra-judicial confession at the police station was compelled under duress, though no medical or other supporting evidence was presented to substantiate claims of torture.
Despite these defenses, both lower courts gave significant weight to the testimonies and the clear circumstantial evidence linking the accused-appellant to the commission of the crime.

Whether the out-of-court and subsequent in-court identifications made by the eyewitness (Juliet) were reliable and sufficient to affirm the accused-appellant’s participation in the crime.
Whether the extra-judicial confession of the accused-appellant, which was not made in compliance with the requirements of R.A. No. 7438, is admissible as evidence.
Whether the defenses of mistaken identity, denial, and alibi raised by the accused-appellant could negate or cast reasonable doubt upon the prosecution’s evidence.
Whether all the essential elements of the special complex crime of Robbery with Homicide, specifically the concurrence of robbery and homicide with qualifying aggravating circumstances, were established beyond reasonable doubt.
How the computed awards for damages (civil indemnity, moral, exemplary, actual damages, and loss of earning capacity) should be adjusted based on the competent proofs provided in the records.