G.R. No. 210316 - Securities and Exchange Commission vs. CJH Development Corp.

On October 17, 1969, during nighttime in Manila, a robbery with homicide occurred.
The crime involved the use of force, violence, and a balisong knife to stab the victim multiple times.
The victim, identified as Manuel de los Santos, was attacked during the commission of a robbery involving the theft of a wrist watch valued at P40.00.
The perpetration of the crime was characterized by the use of violence with intent to kill and to commit robbery, resulting in the victim’s death.

The accused, Rogelio Fuentes y Pitelo, was charged, having been identified also by the alias “Boy Lelit.”
A co-conspirator, Rodolfo Nartea y Apolonio, had also been implicated in connection with the offense.
Testimonies and sworn statements (notably those of Eduardo Lozana and the accused himself via Exhibit “G”) confirmed the identity of Rogelio Fuentes as “Boy Lelit.”
Additional evidence included physical items such as the victim’s wrist watch (retrieved from a buyer) and the balisong knife recovered from one of the conspirators.

Rogelio Fuentes was tried with counsel de oficio.
The trial court, after considering the evidence and testimonies, duly found the accused guilty beyond reasonable doubt as the principal offender in the crime of robbery with homicide.
The trial court identified and considered aggravating circumstances including the use of superior strength and nocturnity.
The sentence imposed was death, along with orders for indemnification to the victim’s heirs (P12,000.00), moral damages (P10,000.00), exemplary damages (P10,000.00), plus costs.

Eyewitness Eduardo Lozana, who was present during the events, directly observed interactions involving the accused and his companions.
The victim’s wife, Carmelita de los Santos, positively identified the wrist watch as belonging to her husband during the incident.
The accused’s own sworn statement explicitly admitted his identity, use of the alias “Boy Lelit,” and his participation in the crime.
The identification was further corroborated by the testimony linking “Lilit” to Rogelio Fuentes, confirming his involvement.

The appellant contended that the trial court erred in equating him with “Boy Lelit,” alleging that the evidence—particularly the testimony of Eduardo Lozana—was ambiguous and suggested the existence of two different persons.
He further advanced an alibi claiming his presence in San Andres Bukid, Manila, during the incident.
However, the appellate record, including his own affidavit (Exhibit “G”), contradicted his defense by establishing his identity as “Boy Lelit.”
The narrative of the events, including the recovery of evidence linking him to the crime scene, further weakened the authenticity of his alibi.

Detailed accounts from police reports, witness statements, and physical evidence (such as blood staining, coins, and remnants from the scene) contributed to the reconstruction of the sequence of events.
Testimonies from police officers and the attached exhibits (e.g., Exhibits “C”, “D1”, “E”, “F”, “G”, and “H”) provided corroborative insights into the timing, location, and nature of the criminal act.
The investigation detailed the movements of other accomplices, the recovery process of the stolen item, and the subsequent apprehension of other suspects, thereby reinforcing the identification of the central accused.

Whether the evidence conclusively establishes that the accused, Rogelio Fuentes y Pitelo, is identical to the person known as “Boy Lelit.”
Whether the reliance on Eduardo Lozana’s testimony adequately proves the accused’s participation under the alias “Boy Lelit.”

Whether the aggravating circumstance of nocturnity was intentionally chosen to facilitate the commission of the crime.
Whether the aggravating circumstance of superiority, based on the number of assailants and physical force, is appropriately sustained by the evidence.

Whether the appellant’s claim of an alibi (being at home in San Andres Bukid) holds probative value against the corroborative evidence linking him to the crime.
Whether his disclaimer of being “Boy Lelit” is credible in light of his sworn admission and other evidentiary requirements.

Whether the mitigating circumstance of intoxication, resulting from a two-hour drinking session, is sufficient to cancel out one or more of the aggravating factors.
How the interplay of aggravating and mitigating circumstances justifies the modification of the penalty from death to reclusion perpetua.