Title
People vs. Chavez y Bitancor
Case
G.R. No. 207950
Decision Date
Sep 22, 2014
Chavez was convicted of homicide, not robbery with homicide, as intent to rob was unproven; 21 fatal stab wounds indicated intent to kill.

Case Digest (G.R. No. 207950)
Expanded Legal Reasoning Model

Facts:

  • Charge and arraignment
    • On November 8, 2006, Mark Jason Chavez y Bitancor was charged with robbery with homicide for allegedly stabbing Elmer Duque y Oros (“Barbie”) multiple times at 1325 G. Tuazon Street, Manila, killing him and taking personal belongings (two cellphones, jewelry, money).
    • At his arraignment on December 4, 2006, Chavez pleaded not guilty; trial ensued before RTC Branch 41, Manila.
  • Crime‐scene observations and evidence collection
    • October 28, 2006, ~2:45 a.m.: Angelo Peñamante, arriving from work, saw a man in black (later identified as Chavez) leaving Barbie’s parlor holding an unknown object, dropped it, and walked away.
    • ~10:00 a.m.: SOCO team led by PCI Sonia Cayrel processed the scene, noted disarray, photographed the body, recovered 155 hair strands from the victim’s hand, and took fingerprints.
    • ~1:00 p.m.: Dr. Romeo Salen’s autopsy revealed 22 wounds (21 stab wounds, 1 incised), four fatal; estimated time of death ~1:00 a.m.
  • Investigation, identification, and trial testimony
    • November 5, 2006: Chavez (22 years old) voluntarily surrendered with his mother; she gave a written statement, surrendered two cellphones of Barbie and a baseball cap.
    • November 6, 2006: Peñamante identified Chavez in a police line‐up; no challenge to the identification procedure was raised.
    • Trial evidence: prosecution witnesses (Peñamante, PCI Cayrel, SPO3 Casimiro, Dr. Salen, Raymund Senofa); defense witness: Chavez (claimed he visited Barbie at ~1:00 a.m. to reconcile a misunderstanding).
    • August 19, 2011: RTC convicted Chavez of robbery with homicide; sentenced to reclusion perpetua without parole and ordered to pay P150,000 in damages.
    • February 27, 2013: CA affirmed the conviction. Chavez appealed to the Supreme Court.

Issues:

  • Whether the evidence established beyond reasonable doubt that Chavez committed the special complex crime of robbery with homicide.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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