Facts:
On or about March twenty-two, nineteen eighty-eight, in Pasay City, Metro Manila,
Romeo Guiraldo y Adlawan and
Venerando Nebreja y Orale, together with other unidentified companions, were charged with
violation of Section 3(b) in relation to Section 1(c) of Presidential Decree No. 532, otherwise known as the
Anti-Piracy and Anti-Highway Robbery Law of 1974, for robbing
Paquito Duenas y Manalaysay and
Romeo Duenas y de Guzman while they were on board an owner-type jeep cruising along a public highway in the city. The information alleged that the accused, armed with a handgun and bladed weapons, conspired and confederated with one another, took and divested cash amounting to
P50,000.00 belonging to the complainants by means of
violence and intimidation, and that as a consequence of the violence, Paquito sustained
mortal wounds that caused his death while Romeo sustained
serious physical injuries. During arraignment, Guiraldo and Nebreja pleaded not guilty, while the other accused’s true names and present whereabouts remained unknown. The prosecution evidence showed that shortly past midnight on March twenty-two, nineteen eighty-eight, Paquito and Romeo left home by jeep toward the slaughterhouse as part of their daily routine. When the vehicle slowed to turn, a man emerged and poked a gun at Paquito, announcing a hold-up; two men boarded the jeep from the rear, and another man positioned himself on the side of Romeo, poking a knife at his neck while motioning him to start the engine. The armed men instructed Romeo to drive to Vitales Street, and the knife-wielding man slashed Romeo’s left arm. On their demand, Paquito handed over money in a bag, and as the jeep moved, the malefactors attacked in concord: Paquito was stabbed on the neck and fell toward the dashboard; Romeo was stabbed on the neck and later suffered multiple knife thrusts, after which Romeo heard a close gunshot that he understood was the fatal shot to his father. Romeo, though wounded, carried Paquito for eight to ten meters, then hailed a pedicab and a taxi to bring them to San Juan de Dios Hospital, where Paquito died at about six o’clock in the morning. A doctor testified that Romeo sustained five stab wounds and required an operation; the injuries could have been inflicted by a single-bladed, sharp-edged, sharp-pointed knife, with a probability that more than one weapon and more than one assailant were used. Police investigators, called to the crime scene after receiving a report from the hospital, found the bloodstained jeep on Vitales Street and recovered a butcher’s knife inside the vehicle; they then conducted questioning that led them to bring Romeo Guiraldo for confrontation, with Eddie Rivera accompanying him, although Romeo was still under sedation when brought to the hospital room. Later, on April eight, nineteen eighty-eight, police investigator Pat. Gil Borcelis directed that Venerando Nebreja, detained in a theft case, be brought to the Investigation Division; upon sight of Nebreja, Romeo broke into tears and shouted that it was the one who stabbed and killed his father. On April ten, nineteen eighty-eight, investigators again brought Romeo Duenas to confront the suspect in their custody; Romeo pointed to Guiraldo as among the men who robbed and attacked, stabbed him, and killed his father, and Nebreja likewise pointed to Guiraldo as the one who asked Nebreja to join in staging a hold-up with companions “Eddie” and “Kiddy,” although both refused to give written statements. A medico-legal officer performed the autopsy on Paquito and found multiple incised wounds and stab wounds and a gunshot wound, with the stab wounds likely caused by a single-bladed knife. The widow,
Mrs. Consuelo Duenas, testified that she incurred hospital and funeral expenses and that Paquito was carrying
P25,000.00 in cash and bank checks which the malefactors took. Romeo testified that he incurred approximately
P50,000.00 for operation and hospitalization. The defense of Guiraldo denied participation and claimed that at dawn of March twenty-two, nineteen eighty-eight, he was at the house of Eddie Rivera, helping purchase hogs and delivering them to the slaughterhouse, and that he was later seized by police for questioning, allegedly subjected to violence when he was detained, and later released; he further claimed that his co-accused did not point to him during the April ten confrontation and that police tried to force him to blame Eddie Rivera as mastermind. In the lower court, Guiraldo was found guilty beyond reasonable doubt as a principal, and he was sentenced to
life imprisonment (reclusion perpetua), jointly and severally liable for certain reimbursement and damages, and costs in equal proportion. Guiraldo appealed. The Supreme Court noted that the appeal was filed only by Guiraldo; Nebreja’s appeal period had lapsed, and entry of judgment was ordered as to Nebreja. The trial court’s decision was affirmed with modifications on the amounts of indemnity and expenses.
Issues:
Whether the conviction of
Romeo Guiraldo y Adlawan was proper in light of the alleged weaknesses in the lone eyewitness identification, the claims of illegal arrest and inadmissibility of evidence arising from it, the admission of alleged custodial statements, and the alleged prejudice due to the continuous trial system, considering the totality of facts.
Ruling:
Ratio:
Doctrine: