Case Digest (G.R. No. 95756)
Facts:
- The case involves People of the Philippines vs. Crisologo Empacis, G.R. No. 95756, decided on May 14, 1993.
- The Regional Trial Court of Cebu City indicted five individuals, including Crisologo Empacis, for robbery with homicide under Article 294 (1) of the Revised Penal Code.
- The incident occurred on September 16, 1986, at around 9:00 PM in Barangay Kanguha, Municipality of Dumanjug, Province of Cebu.
- The indictment alleged that the accused, armed with carbines and bladed weapons, conspired to attack Fidel Saromines, resulting in his death and the theft of P12,000.00.
- During the trial, one accused, Romualdo Langomez, was absent and at large.
- The trial continued with the remaining accused, and Carlito Antiga died from a gunshot wound during the proceedings.
- Crisologo Empacis was convicted, while Zacarias Solis and Bebe Antiga were acquitted due to insufficient evidence.
- The trial court sentenced Empacis to death on October 24, 1989, which was later commuted to reclusion perpetua following the abolition of the death penalty under the 1987 Constitution.
- Empacis was also ordered to pay the heirs of the victim P30,000.00 as death indemnity.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the conviction of Crisologo Empacis, finding sufficient evidence to support the trial court's decision.
- The Court upheld the trial court's appreciation of aggravating circumstances, including dwelling, nighttime, craft or fraud, and superior strength.
- The Court modified the indemnity awarded to the heirs of Fidel Saromines, increasing it from P30,000.00 to P50,000.00 and ordering the restitution of the stolen amount of P12,000.00.
Ratio:
- The Supreme Court found the prosecution's evidence credible, particularly the testimonies of the victim's widow and son, supported by other evidence, including the post-mortem report.
- Empacis' defense was deemed inconsistent and lacking credibility, as he attempted to portray himself as a protector of the victim while participating in the attack.
- The Court noted that conspiracy was evident, with both Empacis and Langomez acting together to rob and kill the victim.
- The aggravating circumstances were properly appreciated, as the crime occurred in the victim's dwelling, at nighttime, and involved deceitful tactics.
- The presence of superior strength was established, as the accused used weapons against an unarmed victim.
- The Court modified the indemnity to align with prevailing jurisprudence, ensuring appropriate compensation for the heirs' loss.
Case Digest (G.R. No. 95756)
Facts:
In the case of People of the Philippines vs. Crisologo Empacis, G.R. No. 95756, decided on May 14, 1993, the Regional Trial Court of Cebu City indicted five individuals, including Crisologo Empacis, for robbery with homicide under Article 294 (1) of the Revised Penal Code. The incident occurred on September 1...