G.R. No. 244843 - People vs. Laguda y Rodibiso

Edgardo Catacutan y Mortera alias “Batibot,” “Enzo” & “Gerry” was charged on September 24–25, 2007 in Quezon City with Robbery with Homicide under Revised Penal Code (RPC) Article 294(1) in relation to Article 293, for stabbing and killing physician Alexander Tan Ngo and taking his personal belongings (DVD player, cellphone, watch, multimedia player, digital camera, cash).
Appellant pleaded not guilty at arraignment; trial ensued before RTC, Branch 101, Quezon City.

Logged appellant’s entry into PND Apartelle at 6:00 p.m. on September 24, 2007 under alias “Gerry” and departure at 6:05 a.m. on September 25; identified appellant in six‐person photo array.

Victim’s classmates found blood‐spattered apartment, unlocked door, TV on high volume; police secured and documented scene.

During October 2007 drinking spree, appellant admitted having sex with victim, retrieving a knife when victim fell asleep, stabbing him repeatedly out of anger over underpayment (₱500 vs. ₱1,000), then stealing items and hiding the knife in the bathroom drain.
Appellant showed Mark the stolen Sony cybershot digital camera; Mark later assisted NBI in appellant’s entrapment and arrest.

NBI Agent Valiant Raganit and PCI Annalee Palima authenticated the 9.5-inch knife recovered from victim’s apartment, security logbook photocopies, and autopsy report showing 25 wounds (three fatal) by sharp instrument.
Victim’s brother Gerry Ngo conducted text‐message entrapment identifying appellant as “Enzo.”

Appellant claimed he was selling barbecue with live-in partner in Sta. Mesa; denied Mark’s account, alleging hostility between them.

Found all elements of Robbery with Homicide proven; convicted appellant to reclusion perpetua without eligibility for parole; awarded ₱100,000 each as civil indemnity, moral, and exemplary damages with 6% interest.

Affirmed RTC, holding circumstantial evidence (logbook ID, Mark’s testimony) sufficient; classified Mark’s testimony as “independently relevant statement” (non-hearsay).

Whether Mark Adalid’s recounting of appellant’s out-of-court confession is admissible as non-hearsay or, at most, as an admission against interest.
Whether the elements of the special complex crime of Robbery with Homicide are present, specifically that the killing occurred by reason of, or on occasion of, robbery (i.e., intent to rob preceded the homicide).
Whether the evidence—security logbook entries, photo identifications, absence of recovered stolen items—is sufficient to sustain conviction beyond reasonable doubt.