Case Digest (G.R. No. 223103)
Facts:
People of the Philippines v. Florentino Labuguen y Francisco alias "Tinong," and Romeo Zuniga y Pilarta, G.R. No. 223103, February 24, 2020, the Supreme Court Second Division, Hernando, J., writing for the Court.The prosecution (plaintiff-appellee) charged appellants Florentino Labuguen y Francisco (Labuguen) and Romeo Zuniga y Pilarta (Zuniga), together with co-accused Rodrigo Macalinao and others, in an Information alleging that on January 3, 2002 in Delfin Albano, Isabela they conspired to commit robbery with homicide and frustrated homicide, entered the victims' home, stole P500,000, and inflicted fatal gunshot and stab wounds on Manuel, Nenita and Rhoda (and serious injuries on Rachelle/Rachel Padre).
On arraignment Labuguen pleaded not guilty; Zuniga initially pleaded guilty but later withdrew and also pleaded not guilty; Macalinao remained at large. During trial the prosecution presented the testimony of surviving victim Rachel (also spelled Rachelle), who described the five assailants, identified Labuguen and, later at the hospital, identified Zuniga; physical evidence included a blood-stained jacket seized from Labuguen that tested positive for human blood group A. Zuniga left Isabela and hid in Gerona, Tarlac, where he was arrested in 2006 and gave a narrative to police.
The Regional Trial Court (Branch 22, Cabagan, Isabela) rendered a Decision dated April 15, 2011 convicting appellants of Robbery with Homicide and sentencing them to reclusion perpetua and ordering damages (Civil indemnity and actual damages to Rachel). The RTC directed issuance of an alias warrant for Macalinao who was still at large. Appellants filed a Notice of Appeal; the Court of Appeals, in a March 25, 2015 Decision in CA-G.R. CR-H.C. No. 04999, affirmed with modification the RTC judgment, ordering the accused jointly and severally to pay Rachel P75,000 for each victim as civil indemnity.
Appellants elevated the matter to the Supreme Court (appeal from th...(Subscriber-Only)
Issues:
- Is appellant Zuniga entitled to the exempting circumstance of irresistible force and/or uncontrollable fear of an equal or greater injury?
- Should the trial court and the Court of Appeals have discredited Rachel's identification of appellants?
- Was there sufficient proof of conspiracy among the assailants?
- Were the elements of robbery with homicide established beyond reasonable doubt?
- Were the penalty and civil damages prope...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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