Case Digest (G.R. No. 138516-17)
Facts:
People of the Philippines v. Emma Dela Cruz y Diaz, G.R. Nos. 138516-17, October 17, 2000, Supreme Court Third Division, Panganiban, J., writing for the Court. The appellant is Emma dela Cruz (accused-appellant), charged with robbery with homicide together with Roger Liad and two other males (Ronnie Locuensio and Doroteo Micul, who remained at large). The Regional Trial Court (RTC) of Quezon City rendered a decision convicting Emma dela Cruz and Roger Liad of robbery with homicide and sentencing them to reclusion perpetua with awards of civil damages; the appellant appealed to the Supreme Court (Notice of Appeal filed April 24, 1999; the case was deemed submitted June 26, 2000).On December 27, 1994 the victims, Norma Lozano and her granddaughter Lorgiza Cristal Velasco, were found stabbed to death in their Quezon City apartment. The private complainant, Malou (Lourdes) Velasco, employed Emma dela Cruz as a maid from October 1994 until late December 1994. On the morning of December 27 a man identifying himself as “Roger” telephoned asking for Emma; later that day witnesses Julio Arguiluz and Samuel dela Cruz observed Emma and three males leave the apartment unit at intervals. Malou returned to find the apartment ransacked and the two victims dead. Autopsies showed multiple fatal stab wounds caused by an 11-inch icepick; an icepick was later recovered in the premises but only on a subsequent date.
An Information indicting Roger Liad was filed January 16, 1995 (Branch 79, RTC-QC); a separate Information charging Emma dela Cruz (and two others) was filed February 24, 1995 (Branch 88, RTC-QC). At trial the prosecution relied primarily on identification testimony (Arguiluz and Samuel dela Cruz), the circumstances at the scene (open maid’s door, ransacked rooms, maid’s belongings missing but her room not ransacked), flight to Samar by Emma, and the alleged recovery of stolen jewelry from Liad. Emma testified she was in Samar and denied knowing Liad; she alleged coercion, lack of counsel during parts of the investigation, and that witness Samuel dela Cruz was paid and coached.
The RTC found the circumstantial evidence constituted an unbroken chain pointing to Emma’s guilt, convicted her and Liad, and awarded actual, moral, exemplary damages and indemnity for the victims’ deaths. On appeal to the Supreme Cour...(Subscriber-Only)
Issues:
- Were the prosecution witnesses' identifications and testimonies sufficiently credible to support conviction despite alleged inconsistencies, payment, and police coaching?
- Was there sufficient proof of conspiracy to convict appellant when (a) items seized from co-accused Liad were obtained after an illegal warrantless arr...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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