Title
People vs. De Jesus y Enrile
Case
G.R. No. 134815
Decision Date
May 27, 2004
A police officer delivering money was abducted, robbed, and killed by a group conspiring to steal $250,000; the appellant was convicted of robbery with homicide and sentenced to death.
A

Case Digest (G.R. No. 194884)

Facts:

  • Background and Context
    • SPO3 Eugenio Ybasco was a policeman assigned to Makati Police Station since 1973 and worked part-time delivering money for a money changer near Ayala Center, Makati.
    • He used a bicycle and carried money in a plastic bag, passing by cigarette vendors including Yolanda dela Rapa, who knew him personally.
  • Conspiracy and Planning of Robbery
    • Defendants Eduardo de Jesus (appellant), Dante Manansala, and Crispin Del Rosario (appellant’s brother-in-law) agreed to stage a robbery on March 7, 1994.
    • The plan involved abducting Ybasco, who was believed to carry US$250,000 daily. Financier Christopher Nash, a British national, provided a Toyota Corolla to use in the operation.
  • Execution of the Crime
    • On March 7, 1994, appellant, Manansala, and Del Rosario arrived in Makati in the car; armed with a .45 caliber handgun, the appellant and Manansala executed surveillance and waited for Ybasco.
    • At about 6:30 p.m., Ybasco was forcibly dragged and handcuffed into the car by Manansala and appellant under the pretense of an arrest.
    • Security guard Roberto Acosta intervened and was shot dead by Del Rosario following instructions from Manansala.
    • After discovering the bag contained only P5,000 instead of US$250,000, Manansala became enraged and struck Ybasco.
    • Ybasco was taken to a sugar farm in Cabuyao, Laguna; the appellant then shot Ybasco in the head while the latter was still handcuffed, causing his death.
    • Del Rosario disembarked in Calamba after receiving money from appellant; appellant remained at large until arrested on November 20, 1995.
  • Investigation and Arrests
    • Witnesses including dela Rapa and Juanito Mendoza gave affidavits identifying the crime and involved persons, including the use of the Toyota Corolla with plate number TAX 732 (later tampered).
    • Del Rosario and Manansala were arrested; Manansala confessed extrajudicially implicating the appellant and others.
    • Del Rosario pleaded guilty; Manansala died in detention from a mauling incident.
    • Appellant denied involvement, provided an alibi corroborated by a witness, but fled to avoid arrest until caught.
  • Trial Proceedings
    • Testimonies from prosecution witnesses, including Del Rosario’s judicial confession dated April 21, 1994, and statements of other witnesses, detailed the conspiracy and events of the robbery with homicide.
    • Appellant’s defense relied on denial, alibi, and claims of personal enmity by Del Rosario, who later sent letters apologizing for implicating him, although these were considered attempts for monetary gain.
    • The court convicted appellant of robbery with homicide and imposed the death penalty, ordering indemnities and damages to victims’ heirs.

Issues:

  • Whether the prosecution sufficiently proved beyond reasonable doubt the appellant’s guilt for robbery with homicide.
  • Whether the trial court erred in admitting and using Del Rosario’s judicial confession against the appellant.
  • Whether the extrajudicial confession of Manansala is admissible evidence.
  • Whether conspiracy among appellant and his cohorts to commit the crime was proven.
  • Whether the appellant’s alibi and denial lacked credibility and were properly disregarded.
  • Whether the aggravating circumstance of treachery was properly applied.
  • Whether the crime of robbery with homicide was properly found despite absence of clear robbery.
  • Whether the imposition of the death penalty was justified given the evidence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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