Case Digest (G.R. No. 130078-82)
Facts:
People of the Philippines v. Maximo Delmo y Isla, Edmund Delmo y Velasquez, Francisco Lapiz y Reyes, and Danilo Lapiz y Reyes, G.R. Nos. 130078-82, October 04, 2002, the Supreme Court En Banc, Quisumbing, J., writing for the Court.These consolidated criminal cases arose from the brutal killings at the Payumo residence in Sta. Rosa, Laguna on September 9, 1995, in which Nancy Payumo and three of her children were stabbed to death and an 11‑year‑old daughter, Helen Grace (Sweet) Payumo, survived grave stab wounds. Following the killings, police investigations proceeded on multiple leads. Acting on an anonymous tip, the PNP detained and interrogated several suspects: Francisco Kit Lapiz (picked up September 13), Danilo Lapiz (brought in September 16), and, subsequently, Maximo and Edmund Delmo (invited for questioning September 17). While in custody, Danilo executed an extrajudicial confession dated September 18, 1995, naming Maximo, Edmund and Francisco; he later retracted it before the MTC on September 25, 1995 alleging torture.
Helen Grace initially executed a Sinumpaang Salaysay on September 25, 1995 identifying three teenagers as perpetrators; she later, on January 18, 1996, changed her statement and named Maximo, Edmund and Francisco as the assailants. After preliminary investigation and prosecutorial review (including a reinvestigation and dismissal of charges against the three teenagers), formal informations for four counts of murder (Criminal Cases Nos. 9453‑56‑B) and one count of frustrated murder (Criminal Case No. 9457‑B) were filed against Maximo, Edmund, Francisco and Danilo.
At trial the prosecution relied principally on Helen Grace’s in‑court identification and narrative of the events; the defense offered denials and alibi testimonies corroborated by family members and neighbors. The Regional Trial Court, Binan, Laguna, Branch 24, rendered a consolidated decision dated March 20, 1997, convicting Maximo, Edmund and Francisco as principals of four counts of murder and one count of frustrated murder and sentencing them (the RTC imposed death on murder counts), while finding Danilo guilty only as an accomplice and sentencing him to reclu...(Subscriber-Only)
Issues:
- Was the extrajudicial confession of Danilo Lapiz admissible against him and his co‑accused?
- Was the lone surviving eyewitness, Helen Grace Payumo, a credible witness whose in‑court identification could support conviction?
- Was the prosecution’s evidence sufficient to convict appellants Maximo Delmo, Edmund Delmo and Francisco Kit Lapiz as principals, and to convict Danilo Lapiz?
- Were the penalties and damag...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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