Case Digest (G.R. No. 204894)
Facts:
- On September 4, 2006, murder charges were filed against Noel Enojas y Hingpit, Arnold Gomez y Fabregas, Fernando Santos y Delantar, and Roger Jalandoni y Ari in the Las Piñas RTC (Criminal Case No. 06-0854).
- The incident occurred on August 29, 2006, when police officers PO2 Eduardo Gregorio, Jr. and PO2 Francisco Pangilinan noticed a suspicious taxi driven by Enojas.
- Upon questioning, Enojas fled during a shootout with suspected robbers, resulting in the death of PO2 Pangilinan.
- Enojas abandoned his taxi, leaving behind a mobile phone, which led to the arrest of Santos and Jalandoni through monitored messages.
- The prosecution presented evidence, including text messages linking the accused to the crime.
- The father of the deceased officer testified about the financial impact of his son's death.
- The accused did not present evidence but claimed illegal arrest and inadmissibility of text messages.
- On June 2, 2008, the RTC convicted all accused of murder, citing evident premeditation and armed men, sentencing them to reclusion perpetua and ordering damages to the victim's heirs.
- The Court of Appeals affirmed the conviction but found no evident premeditation, leading to an appeal to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court found sufficient circumstantial evidence to establish the guilt of the accused beyond a reasonable doubt.
- The Court ruled that the admission of the text messages was proper under the Rules on Electronic Evidence.
- The Court disagreed with the Court of Appeals regarding aggravating circumstances, ruling that the accused were liable for homicide aggravated by the use of unlicensed firearms....(Unlock)
Ratio:
- The Supreme Court emphasized that circumstantial evidence can lead to conviction if it meets specific criteria: multiple circumstances, proven facts leading to inferences, and a combination of circumstances supporting a conviction beyond reasonable doubt.
- In this case, the circumstantial evidence, including Enojas's identification as the taxi driver, his flight, and incriminating text messages, e...continue reading
Case Digest (G.R. No. 204894)
Facts:
On September 4, 2006, the City Prosecutor of Las Piñas filed murder charges against Noel Enojas y Hingpit, Arnold Gomez y Fabregas, Fernando Santos y Delantar, and Roger Jalandoni y Ari before the Las Piñas Regional Trial Court (RTC) in Criminal Case No. 06-0854. The case arose from an incident that occurred on August 29, 2006, when PO2 Eduardo Gregorio, Jr. and PO2 Francisco Pangilinan were patrolling near Toyota Alabang and SM Southmall. They noticed a taxi, driven by Enojas, parked suspiciously in front of Aguila Auto Glass. Upon questioning Enojas about his documents, the officers became suspicious and asked him to accompany them to the police station for further inquiry. Enojas complied but fled when a shootout erupted between PO2 Pangilinan and two suspected robbers, resulting in Pangilinan's death.
Following the incident, the police discovered Enojas had abandoned his taxi, leaving behind a mobile phone. The police monitored the phone's messages, which led to the entrapment and arrest of Santos and Jalandoni. Enojas and Gomez were later apprehended as well. The prosecution presented evidence, including text messages that linked the accused to the crime. The father of the deceased officer testified about the financial impact of his son's death, detailing expenses incurred for burial and interment. The accused opted not to present evidence in their defense, instead filing a trial memorandum claiming illegal arrest and inadmissibility of the text messages. On June 2, 2008, the RTC convicted all accused of murder, citing evident premeditation and the use of armed men, and sentenced them to reclusion perpetua and ordered them to pay damages to the victim's heirs. The Court of Appeals affirmed the convicti...