Case Digest (G.R. No. 194884)
Facts:
This case involves the appellant, Eduardo de Jesus y Enrile, charged with robbery with homicide for his alleged participation in the abduction, robbery, and subsequent killing of SPO3 Eugenio Ybasco, a policeman who worked part-time as a money courier for a money changer, and the killing of a security guard, Roberto Acosta, who attempted to intervene. The crime occurred around March 7, 1994, in Makati City.
The prosecution presented evidence that Eduardo de Jesus conspired with co-accused Crispin Del Rosario (his brother-in-law) and Dante Manansala to ambush Ybasco while he was delivering money, intending to steal US$250,000 believed to be in Ybasco’s possession. The group used a white Toyota Corolla car owned by British national Christopher Nash, who was later removed from the charges.
On the evening of March 7, 1994, the trio executed their plan, forcefully abducting Ybasco, handcuffing him, and dragging him into the vehicle. During the ordeal, security guard Acosta tried to
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)