G.R. No. L-10104 - People vs. Corpuz

Case Digest (G.R. No. L-10104)
Expanded Legal Reasoning Model

Facts:

Background of the Case

The case involves two criminal proceedings consolidated by the Court of First Instance of Abra:

Criminal Case No. 385 – Charges of robbery with homicide against Severino Corpuz, Luis Ardaniel, and two unidentified persons.
Criminal Case No. 406 – Charges against Pascual Gallardo for the same offense, where Gallardo was eventually acquitted.

Upon arraignment, all accused pleaded not guilty.

Description of the Crime

Date and Time:

The incident occurred on the evening of May 2, 1952, between 11:00 and 12:00 o’clock.

Location:

The crime was committed at the residence of ex-mayor Antonio Castaneda in barrio Alimodong, La Paz, Abra.
The household included Castaneda’s wife Carmen, daughter Aniceta, son Jovencio, and sister-in-law Juanita Balicao.

Sequence of Events:

The family was awakened by two armed men carrying carbines.
The intruders did not identify themselves and instead ordered the household to comply by standing up.
They forced the victims to provide something to eat and proceeded to rob the family’s savings and personal belongings.

Seized items included:

Savings of P130.00 hidden under a mat.
Earrings and a ring from both Carmen and Juanita Balicao (each valued at P70.00).
A Bulova wrist watch valued at P200.00 from Antonio Castaneda.

Acts of Violence Committed:

Appellant Luis Ardaniel was noted to have specifically targeted Aniceta by taking her to the kitchen, eating food with her, and then questioning her about her menstruation, which indicated an intent to further abuse her.
When Aniceta attempted to escape, Ardaniel restrained her by seizing her dress, pointing a gun, and kicking her.
Antonio Castaneda, upon intervening to protect his daughter, was ordered to remove his clothes and lie face downward along with the other victims.
Despite the orders, Castaneda was lying on his side, prompting Ardaniel to fire two shots followed by three additional shots from Corpuz, ultimately causing Castaneda’s death.

Medical Evidence:

A post mortem examination conducted by Dr. Julio P. Valera revealed:

The victim sustained five gunshot wounds, with four being fatal.

ii. The wounds were described in detail, indicating entry and exit points along with a burn mark around one of the entrance wounds. iii. The cause of death was determined to be shock and hemorrhage.

Evidence and Testimonies

Identification of the Perpetrators:

Carmen Castaneda, the victim’s wife, identified Severino Corpuz from prior acquaintance.
Aniceta Castaneda, the victim’s daughter, identified Luis Ardaniel as one of the assailants.
Other witnesses, including Juanita Balicao and neighbor Rosalina Tawagan, supported the identification:

Juanita Balicao recognized Ardaniel as the person who had taken her earrings and ring.

ii. Rosalina Tawagan testified to hearing gunshots and later observing Ardaniel leaving through a ladder.

Defendant’s Alibi:

Luis Ardaniel claimed he was at the house of Esperanza Barsuela in barrio Balintong, San Juan, Abra, playing the trumpet in a band during a death anniversary celebration and dance.
His alibi was supported by testimonies of Esperanza Barsuela and Alejandro Billedo, who confirmed his alleged presence at the gathering.

Contradictory Nature of the Evidence:

The prosecution’s positive identification and direct testimonies from the victim’s family and neighbors carried substantial weight.
The alibi presented by Ardaniel was found to be unconvincing and not supported by indubitable evidence.

Trial Outcome

Judgment in Criminal Case No. 385:

Severino Corpuz and Luis Ardaniel were found guilty beyond reasonable doubt of robbery with homicide.
The sentencing for both included:

Reclusion perpetua as the principal penalty.

ii. Payment of P6,000.00 to indemnify the heirs of the deceased Antonio Castaneda. iii. The requirement to return the stolen articles or, if unable, to pay the corresponding monetary value of such articles. iv. Imposition of accessory penalties as provided by law.

Being ordered to pay the costs.

Judgment in Criminal Case No. 406:

Pascual Gallardo was acquitted on grounds of reasonable doubt, with costs de oficio.

Post-Trial Proceedings:

Both Corpuz and Ardaniel appealed their convictions.
Corpuz’s appeal was dismissed following his motion on June 24, 1959, while Ardaniel’s appeal was not successful.

Issues:

Validity and Credibility of Witness Testimonies

Whether the direct identifications made by the victims’ relatives and neighbors were reliable and free from bias.
The consistency between the statements given during trial and those made immediately after the incident.

Credibility of the Defendant’s Alibi

Whether Luis Ardaniel’s claim of performing at a death anniversary celebration sufficiently refuted his presence at the crime scene.
The evidentiary support (or lack thereof) for Ardaniel’s alibi as presented by his witnesses.

Establishment of Guilt Beyond Reasonable Doubt

Whether the prosecution managed to establish that the accused were indeed present at the scene and actively participated in the commission of the crime.
The relevance of physical evidence and forensic findings (as in the post mortem report) in corroborating the testimonies.

Application of Aggravating Circumstances

Whether the circumstances such as nocturnity and treachery were adequately demonstrated to justify the imposition of reclusion perpetua.
The sufficiency of evidence supporting the commission of the offense with aggravating circumstances despite the failure to secure the number of votes required for the death penalty.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. L-10104) Core Legal Reasoning Model Expanded

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Case Digest (G.R. No. L-10104) Expanded Legal Reasoning Model

Facts:

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Doctrine:

Case Digest (G.R. No. L-10104)
Core Legal Reasoning Model

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Case Digest (G.R. No. L-10104)
Expanded Legal Reasoning Model