Title
Supreme Court
People vs. De Leon
Case
G.R. No. 197546
Decision Date
Mar 23, 2015
Accused-appellants convicted of Murder for killing Emilio Prasmo; self-defense rejected, robbery unproven, double jeopardy violated in robbery charge.

Case Digest (G.R. No. 197546)
Expanded Legal Reasoning Model

Facts:

  • The Incident and Charges
    • The crime occurred on or about March 2, 2002, in Quezon City, Philippines.
    • The Information charged the accused-appellants—Bayani de Leon, Antonio de Leon, Danilo de Leon, and Yoyong de Leon—with Robbery with Homicide.
    • The accused-appellants, who are siblings, allegedly conspired to rob and kill the victim, Emilio A. Prasmo.
    • The charging document detailed that during the incident, the accused used a variety of weapons (sumpak, samurai, lead pipe, and a .38 caliber revolver) to attack Emilio, inflict serious wounds, and ultimately cause his death.
    • At arraignment, all injected a plea of not guilty with the exception of Antonio, whose plea of self-defense led to a reverse trial concerning his case.
  • Prosecution’s Case and Evidence
    • Eyewitness Testimony
      • Erlinda A. Prasmo, the victim’s wife, testified that she and her husband were ambushed while walking along Sta. Lucia Street.
      • Her account described how the accused-appellants, with multiple weapons in hand, attacked Emilio, first by hitting and then by hacking him, which resulted in serious and fatal wounds.
    • Corroborative Testimonies and Documentary Evidence
      • Gina Prasmo, Emilio’s daughter, provided eyewitness confirmation regarding the sequence of events.
      • The Medico-Legal Report and accompanying documents (autopsy report, anatomical sketches, and medico-legal report) demonstrated the nature and severity of Emilio’s injuries.
    • Physical Evidence and Weapon Identification
      • Testimonies indicated that accused Danilo assaulted Emilio with a sumpak by suddenly hitting him.
      • Accused Antonio was implicated as having used a samurai and lead pipe, while accused Yoyong was similarly implicated in striking the victim with a lead pipe.
    • Evidence of Armed Confrontation and Escape
      • As the accused-appellants attacked and left the scene, the victim was transported to the FEU Fairview Hospital, where he later succumbed to his injuries.
      • Additionally, there was evidence of intimidation when, after the attack, a bystander testified to hearing shouted orders and witnessing the rapid departure of the assailants.
  • Defense’s Case and Testimonies
    • Alternative Account by a Family Member
      • Carmelita de Leon, sister to the accused-appellants, testified regarding events the evening before the attack, stating that Danilo and Antonio arrived injured from an earlier altercation with Emilio and his son Edgardo.
      • She mentioned an incident at her home where a group of fifteen armed men later threatened her, claiming to be related to the Prasmo family.
    • Self-Defense and Alibi Arguments
      • The defense presented that Antonio acted in self-defense, claiming that Emilio, upon encountering him on the street, had initiated an aggressive confrontation by pulling “something” from his jacket.
      • The accused provided alibi accounts:
        • Yoyong testified to being at a relative’s house discussing the schedule of a “pabasa.”
        • Danilo claimed he was with his mother in Pugad Lawin during the time of the crime.
        • Bayani asserted he was at the Police Station No. 5, Fairview, conversing with a police officer.
    • Documentary Support for the Defense
      • Medical certificates confirmed injuries allegedly sustained by Danilo and Antonio in an earlier altercation.
      • An entry in the barangay blotter corroborated the mauling incident reported on March 2, 2002.
  • Trial Court Proceedings and Findings
    • The Regional Trial Court (RTC) conducted a reverse trial with attention to both the prosecution’s evidence and the inconsistencies in Erlinda’s testimony (notably between her court testimony and her Sinumpaang Salaysay).
    • The RTC found that, although some inconsistencies existed, they were minor and did not detract from the overarching, clear narrative of a planned assault.
    • It ruled that the elements of robbery were not sufficiently established; hence, a conviction for Robbery with Homicide was untenable.
    • Instead, the RTC convicted the accused-appellants of Murder by Conspiracy under Article 248 of the Revised Penal Code.
    • The RTC also ordered the imposition of reclusion perpetua and mandated the payment of indemnity and damages (including P50,000.00 each as indemnity and moral damages) to the heirs of Emilio Prasmo.
  • Post-Trial Developments and Appellate Rulings
    • The Court of Appeals (CA) affirmed the RTC’s finding of guilt for Murder for all accused-appellants.
    • The CA, however, modified the judgment by additionally convicting accused-appellant Danilo for the crime of Robbery, considering it an independent act from the original charge.
    • On automatic review, the accused-appellants challenged:
      • The credibility and inconsistencies of Erlinda’s testimony.
      • The self-defense plea of Antonio.
      • The violation of double jeopardy concerning Danilo’s additional conviction for robbery, given his previous acquittal on that charge.

Issues:

  • Credibility and Inconsistency in Witness Testimony
    • Whether the discrepancies in Erlinda A. Prasmo’s testimony—between her Sinumpaang Salaysay and her in-court testimony—are sufficient to undermine her overall credibility.
    • The impact of these discrepancies on the prosecution’s case for establishing the elements of murder and robbery.
  • Validity of Self-Defense Claim
    • Whether accused-appellant Antonio’s plea of self-defense is legally sustainable based on the evidence.
    • Whether the act of Emilio pulling out “something” from his jacket constitutes “unlawful aggression” justifying self-defense.
  • Establishment of Robbery as an Essential Element
    • Whether the evidence conclusively proves the crime of robbery as an independent element alongside homicide.
    • If the failure to conclusively establish robbery precludes a conviction for Robbery with Homicide.
  • Double Jeopardy Implications
    • Whether convicting accused-appellant Danilo for robbery in addition to murder violates the constitutional prohibition against double jeopardy.
    • Whether the RTC’s acquittal of Danilo for robbery—due to insufficient evidence—amounts to a final judgment that should bar a subsequent conviction on the same charge.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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