Case Digest (G.R. No. 260731)
Facts:
People of the Philippines v. Edgardo Catacutan y Mortera alias "Batibot", "Enzo" & "Gerry", G.R. No. 260731, February 13, 2023, Supreme Court Second Division, Lazaro-Javier, J., writing for the Court.Appellant Edgardo Catacutan was charged in Quezon City (Criminal Case No. Q-08-153138) with Robbery with Homicide under Article 294(1) in relation to Article 293 of the Revised Penal Code for the killing of Alexander Tan Ngo on or about 24–25 September 2007 at the PND Apartelle. The Information alleged that appellant, with treachery, evident premeditation and abuse of superior strength, stabbed Alexander multiple times, causing mortal wounds, and thereafter took several personal items and cash.
At trial the prosecution presented several witnesses: security guard Alfredo Ortiz Koh, classmates and friends (including Robert Ramos and Mark P. Adalid), NBI Agent Valiant Raganit, PCI Annalee Palima (medico-legal officer), and private complainant Gerry Ngo (the victim’s brother). Koh testified he logged appellant’s arrival (6:00 p.m., Sept. 24) and departure (6:05 a.m., Sept. 25) as Alexander’s visitor. Robert and classmates discovered Alexander’s body on Sept. 25. Mark testified that appellant (whom he called “Batibot”) admitted during a drinking spree that he killed Alexander after a sexual encounter and later took Alexander’s possessions; Mark also identified a Sony digicam that appellant had and recalled appellant’s statements about hiding the knife and disposing of his briefs. The NBI recovered a 9.5-inch knife from the victim’s comfort room trap, and the autopsy showed multiple sharp-force injuries including fatal wounds.
Appellant denied the charges, claiming he was elsewhere selling barbecue with his partner on the relevant days and disputing Mark’s account. The Regional Trial Court, Quezon City, Branch 101, rendered an Amended Decision dated June 29, 2018 finding appellant guilty of Robbery with Homicide and sentencing him to reclusion perpetua without eligibility for parole, and ordering monetary damages to the heirs of Alexander Tan Ngo.
The Court of Appeals, in CA-G.R. CR-HC No. 11631, affirmed by Decision dated January 26, 2021, upheld appellant’s conviction for the special complex crime of robbery with homicide, finding the information sufficient and that the circumstantial evidence, including Koh’s identification and Mark’s narrative (which the CA treated as an independently r...(Subscriber-Only)
Issues:
- Is Mark’s testimony recounting appellant’s out-of-court statements admissible against appellant as an admission or as an independently relevant statement?
- Did appellant commit the special complex crime of Robbery with Homicide under Article 294(1) in relation to Article 293 of the Revised Penal Code, or are the facts properly characterized as separate ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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