G.R. No. 138516-17 - People vs. Dela Cruz

The case involves the conviction of Emma dela Cruz and Roger Liad for the special complex crime of robbery with homicide, punishable under Article 294 of the Revised Penal Code as amended by R.A. 7659.
The Regional Trial Court (RTC) of Quezon City, in its January 22, 1999 Decision, sentenced both accused to reclusion perpetua and imposed civil liabilities including actual, moral, exemplary damages and indemnity for the death of the victims.
The case centers on the events of December 27, 1994, when a violent robbery at the residence of Norma Lozano y Dominguez resulted in the deaths of Norma and her daughter Lorgiza Cristal Velasco.

Emma dela Cruz was employed as a maid by private complainant Malou Velasco (also known as Lourdes Lozano-Velasco), who had engaged her services since September 1994.
On December 23, 1994, the De la Cruz sisters requested a Christmas vacation and were given their salaries and bonuses; Malou temporarily departed, leaving the victims in the residence.

Emma dela Cruz had been seen inside the apartment prior to the crime when a telephone call was made by a man identifying himself as Roger, suggesting that both Riza (the sister of Emma) and their mother were going to the Visayas.
Approximately at 9:00 in the morning, as the private complainant was about to leave for work, some unusual occurrences were noted: the front door and windows of the apartment were secured, while the side door (leading to the maid’s quarters) was open.
After returning later that day, the private complainant discovered disarray in the apartment: the telephone cord was cut, personal belongings were scattered, and most notably, the lifeless, bloodied bodies of Norma and Lorgiza were found, indicating that they had been stabbed multiple times.

The prosecution relied primarily on circumstantial evidence and the testimonies of key witnesses, including Samuel dela Cruz and Julio Arguiluz, who provided details on the movements of persons around the crime scene.
Witnesses observed that after Malou left for work, the accused Emma dela Cruz was seen emerging from the apartment, ostensibly to dispose of garbage, and shortly thereafter, three males (one later identified as Roger Liad) were seen leaving the premises at intervals.
A series of events—including a phone message implicating Emma, the layout of the apartment (with the maid’s quarters open while the main access points were closed), and the recovery of stolen jewelry from Liad—formed the basis for the inference of conspiracy and participation in the robbery and subsequent homicide.

Autopsy reports on the victims detailed multiple stab wounds as the cause of death, with forensic evidence indicating that the injuries were inflicted using an 11-inch ice pick.
Circumstantial evidence, including recovered stolen items and the condition of the apartment, corroborated the narrative of a well-orchestrated crime.

Emma dela Cruz claimed she was not present at the crime scene on December 27, 1994, asserting she had already left for Matuguinao, Samar.
She denied any knowledge of, or association with, her co-accused Roger Liad, stating that she was only later introduced to him upon incarceration.

The defense argued that there were glaring inconsistencies between the testimonies of prosecution witnesses (Samuel dela Cruz and Julio Arguiluz).
It was contended that one of the key witnesses, Samuel dela Cruz, was a paid witness whose testimony was unreliable and that the police had allegedly coached him by providing details of the suspects’ identities.

The defense raised concerns over the legality of the arrest of Roger Liad and the subsequent seizure of evidence, contending that the warrantless arrest and search rendered the recovered stolen items inadmissible under the exclusionary rule.

Emma dela Cruz was the only member of the household who remained unharmed despite being present at the scene, suggesting deliberate exclusion from the victims of violence.
The physical layout of the apartment (with a distinct entrance to the maid’s quarters) and the testimonies showing her presence at critical moments implied shared complicity with the male co-accused.
Her flight to Samar immediately after the incident further suggested an attempt to avoid accountability in connection with a joint criminal enterprise.

Whether the testimonies of prosecution witnesses, particularly Samuel dela Cruz and Julio Arguiluz, were consistent and credible in reconstructing the events of December 27, 1994.
The contention that witness Samuel dela Cruz was a paid witness, with potential coaching by the police, thereby affecting the reliability of his identification of the accused.

Whether there was sufficient circumstantial evidence to establish that a conspiracy existed among the accused, linking Emma dela Cruz, Roger Liad, and the other alleged participants in a joint criminal enterprise.
The adequacy of the evidence (including the chain of circumstantial facts and the actions at the crime scene) to sustain a conviction for robbery with homicide, especially in the absence of direct evidence.