G.R. No. 115401 - People vs. Fabula

On August 24, 1992, at around 8:00 in the evening, an elderly couple—spouses Mariano Cueto and Petra Cueto—was robbed and fatally stabbed near their residence at Barangay Gamao, Naujan, Oriental Mindoro.
The crime occurred during a robbery where the accused, Edilberto “Eden” Fabula (among others still at large), participated in the commission of the offense.
The prosecution charged the accused with Robbery with Double Homicide under Article 294, paragraph 1 of the Revised Penal Code.

Bernardo Lingasa, an eyewitness, testified that while at the house of the Cueto spouses, he heard Petra scream and observed Edilberto Fabula grabbing Petra’s bag.
He further noted that Fabula stabbed Petra in the chest and, during the ensuing commotion, another accomplice attacked Mariano by holding his neck and stabbing him.
Fabula’s explicit remark, “Tayo na Kuya Kano, patay na yang mga yan,” indicated a call to action against the victims.

Danilo Cueto, son of the deceased couple, testified that on August 23, 1992, he saw his mother counting money (amounting to P15,000) and placing it in her bag, which later went missing after the incident.
These testimonies established a direct link between the violent act and the accused’s actions, reinforcing the theft and fatal stabbing.

Among the accused, only Edilberto Fabula was arraigned and tried, while his co-accused remained at large.
During the trial, despite the accused’s defense of denial and issuance of an alibi (claiming he was at his parents’ house in Sta. Cruz, Calapan), the eyewitness identification and other evidence prevailed.
The trial court convicted Fabula, sentencing him to two terms of reclusion perpetua—one for the death of Mariano Cueto and another for the death of Petra Cueto—and ordering him to pay P100,000 as indemnity to the victims’ heirs.

In the appeal, the accused-appellant contended that the prosecution had twisted facts and suppressed material evidence favorable to him.
He further assailed the credibility of the eyewitnesses by pointing out inconsistencies in their testimonies, and he relied on an alibi defense.
However, his appellate brief was found deficient as it violated the requirements of the Rules of Court—specifically, Rule 46, Section 16—which mandates a subject index, clear assignment of errors, and properly stated issues, among other formalities.

Despite the defense’s allegations, the eyewitness testimony of Bernardo Lingasa was clear and unequivocal, leaving no room for reasonable doubt.
The trial court erred in ordering separate penalties for each homicide, as the law dictates a unified penalty for the special complex crime of robbery with homicide.
It was also noted that the trial court failed to order the return of the P15,000 forcibly taken during the robbery, a sum which the Supreme Court later stipulated should be paid as part of the indemnity.

Whether the accused-appellant’s brief complied with the mandatory requirements of Section 16, Rule 46 of the Rules of Court regarding the statement of case, statement of facts, assignment of errors, and indication of relief sought.

Whether the eyewitness identification by Bernardo Lingasa was sufficient to overcome the accused’s defense of denial and the uncorroborated alibi.
Whether the inconsistencies alleged by the accused in the prosecution witnesses’ testimonies were significant enough to establish reasonable doubt.

Whether the accused should be sentenced for “Robbery with Double Homicide” as two separate offenses or whether all acts of homicide, committed on the occasion of the robbery, should be merged into one integrated offense under Article 294 of the Revised Penal Code.