Case Digest (G.R. No. 219581)
Facts:
In People of the Philippines vs. Maximo Dela PeAa, G.R. No. 219581, decided January 31, 2018, the *People* charged appellant Maximo Dela PeAa with piracy under Presidential Decree No. 532. On September 24, 2005, at about 1:00 a.m., along the riverbank of Barangay San Roque, Municipality of Villareal, Samar, four armed men blocked a pump boat owned by Julian and Jose Nacoboan, who were ferrying 13 sacks of copra to a larger vessel. One assailant, later identified by the victim Julita Nacoboan as Maximo Dela PeAa—whom she had known for 16 years—pointed a firearm at Jose, bound his hands, and forced the couple and their son Marwin to travel to two islands. There the intruders unloaded the 13 sacks of copra, removed the boat’s engine, propeller tube, and tools, and seized Julita’s gold jewelry, wristwatches, cellphone, and ₱1,000 in cash. Left without power, the victims paddled to safety and reported the incident to police. At the Regional Trial Court (RTC) of Calbiga, Samar (CriminCase Digest (G.R. No. 219581)
Facts:
- Parties and Procedural Posture
- Plaintiff-Appellee: People of the Philippines; Accused-Appellant: Maximo De La PeAa; Co-accused fugitives: Romy Real, Danny Real, Onyong Reyes.
- RTC of Calbiga, Samar, Branch 33, convicted appellant of piracy under PD No. 532 by Decision dated October 22, 2007; CA affirmed with modification on December 16, 2014; appellant appealed to the Supreme Court.
- Prosecution’s Version
- On September 24, 2005 at ~1:00 a.m., victims Julita, Jose, and Marwin Nacoboan were transferring 13 sacks of copra by pump boat along the river bank of Brgy. San Roque, Villareal, Samar (a river forming part of Philippine waters).
- A smaller boat blocked their path; three armed men—one identified as appellant—boarded, tied Jose, pointed a firearm, seized 13 sacks of copra (₱7,537), a 16-HP engine with propeller (₱26,000), tools, two watches (₱6,796), a gold pendant (₱4,731), a Nokia 3350 phone (₱3,615), and ₱1,000 cash; they transported the loot to nearby islands, leaving the victims stranded.
- Julita filed a report the next day, valuing copra at ₱15/kg and engine/equipment at ₱30,000; she positively identified appellant, whom she had known for 16 years.
- Defense’s Version
- Appellant claimed alibi: from September 5 to December 5, 2005, he was in Daram, Samar doing “finishing” work and stayed with Barangay Kagawad Edgar Pojas; he used another man’s boat to fish and returned home daily.
- He denied participation, asserted four soldiers arrested him on December 6, 2005, and noted he did not know co-accused Real and Reyes.
- Rulings Below
- RTC found prosecution witnesses credible, rejected alibi, sentenced appellant to reclusion perpetua without parole and awarded damages (actual, exemplary, moral, nominal).
- CA denied appeal, modified damages: awarded ₱30,000 temperate damages, deleted actual, moral, nominal, and exemplary damages; imposed 6% interest; affirmed reclusion perpetua without parole.
Issues:
- Whether appellant is guilty beyond reasonable doubt of piracy under PD No. 532.
- Whether the penalty and damage awards imposed by the courts below are proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)