Case Digest (G.R. No. 111124)
Facts:
People of the Philippines v. Juan Salvatierra, Enrique Constantino, Agustin Trinidad, Willie Trinidad, and Alvin Santos, G.R. No. 111124, June 20, 1996, the Supreme Court Second Division, Regalado, J., writing for the Court. The prosecution charged five persons with a complex crime arising from a May 15, 1988 armed entry into the Makati residence of Japanese national Hichiro Kubota and his common‑law wife Elizabeth Hammond, in which jewelry and cash were stolen, Kubota and maid Hazel (Cecille) Arjona were fatally stabbed, and another maid, Marilyn Juguilon, was wounded.An amended information dated August 11, 1988 alleged that the accused, conspiring together, entered the house while armed and committed robbery with rape, double homicide and attempted homicide. At trial only three of the five accused were brought to trial (Salvatierra, Constantino and Agustin Trinidad); Willie Trinidad and Alvin Santos remained at large. Salvatierra was arraigned and tried first (arraigned August 31, 1988); Constantino and Agustin were arraigned later (March 15 and May 30, 1990, respectively). Witnesses for the prosecution included Elizabeth Hammond, Epifania Hammond, Diosa Hammond and Marilyn Juguilon; medical and police witnesses also testified. Each accused testified in his own defense.
The Regional Trial Court, Branch 56, Makati, rendered judgment on January 22, 1993 finding Enrique Constantino and Juan Salvatierra guilty beyond reasonable doubt of robbery with homicide under Article 294(1) of the Revised Penal Code and acquitting Agustin Trinidad. The RTC sentenced Constantino and Salvatierra to reclusion perpetua and ordered civil indemnities and reimbursement for the stolen property; it ordered Agustin’s release. Constantino, the lone indictee who pursued appellate review, appealed to this Court asserting (among other things) that he acted under duress (coerced by Salvatierra’s knife) and challenging the trial court’s credibility findings; he a...(Subscriber-Only)
Issues:
- Did the trial court err in disbelieving appellant Enrique Constantino’s claim of duress and in accepting the prosecution witnesses’ identifications and testimonies?
- Was conspiracy established such that the acquittal of co‑accused Agustin Trinidad does not absolve Constantino of liability?
- Was the crime correctly characterized as the special complex crime of robbery with homicide an...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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