G.R. No. 121532 - People vs. Lacatan

On November 23, 1990, between 8:00 and 8:30 in the evening, the accused—Rommel Lacatan, Ruby Villamarin, and Dominador Salazar—allegedly committed a robbery with homicide at the residence and store of Alfredo Salazar in Barangay G. Antonio, Municipality of Gloria, Oriental Mindoro.
The crime involved a conspiracy where the accused, armed with a bladed instrument (agulukana), forcibly entered the premises, took cash money, assorted jewelries, and foodstuffs amounting to a total of P170,000.00, and in the process, fatally stabbed Alfredo Salazar.
Aggravating circumstances identified in the incident included evident premeditation, treachery, abuse of superior strength, nocturnity, and cruelty.

Eduardo Ruallo, an eyewitness and long-time customer of the victim, testified that he observed the accused inside the residence. He detailed how Ruby Villamarin and Dominador Salazar were holding the victim’s arms while Rommel Lacatan repeatedly stabbed Alfredo Salazar with the agulukana.
Additional testimonies were provided by the victim’s family members (Elmer Salazar, Edna Salazar, and Anicia "Ka Alpe" Salazar), who recounted the discovery of the crime scene—broken household items, scattered money and jewels, and the lifeless body of Alfredo Salazar found in the bathroom.
Patrolman Delfin Yumang’s photographic evidence captured the scene including the victim’s body, the disheveled state of the aparador, and other disturbed areas within the premises.
Dr. Edgardo N. Hernandez’s autopsy report confirmed that the victim suffered multiple stab and incise wounds, indicating the use of at least two weapons.

The accused entered negative pleas upon arraignment and later raised defenses based on denial and alibi.
Dominador Salazar testified that he was occupied in his brother-in-law’s fields and later drank tuba, while Ruby Villamarin and Rommel Lacatan claimed that they were busy constructing a house and later went home with their families.
Additional defense witnesses, Rodolfo Umbao and Ruel Suppleo, sought to discredit the credibility of eyewitness Eduardo Ruallo by alleging inconsistencies—such as the location of the victim’s body and the absence of bloodstains at certain areas.

Records established that all three accused were residents of Tinalunan, Gloria, with their domiciles in close vicinity to the crime scene, thereby undermining the defense’s claim of a verifiable alibi due to geographical impossibility.
The cumulative evidence consisted of eyewitness identification, physical evidence from the crime scene, and documented discrepancies in the alibi claims of the accused.

The trial court, Branch 42 of the Regional Trial Court in Pinamalayan, Oriental Mindoro, found the accused guilty beyond reasonable doubt of robbery with homicide under Article 294, paragraph 1 of the Revised Penal Code.
In addition to the conviction, the trial court sentenced each accused to suffer reclusion perpetua and imposed financial indemnification and restitution to the heirs of Alfredo Salazar.
The trial court gave full faith and credit to the testimonies of prosecution witnesses despite the defense’s efforts to question the credibility and consistency of the eyewitness accounts.

Whether the testimony of eyewitness Eduardo Ruallo, despite claims of inconsistency regarding details (such as the exact location where the victim was dragged and the absence of bloodstains in certain areas), was sufficient to establish guilt beyond reasonable doubt.
Whether a single eyewitness, whose account was not corroborated by any other witness in a similar capacity, could reliably serve as the foundation for convicting the accused.

Whether the alibi presented by the accused—asserting that they were elsewhere (constructing a house or engaged in other activities away from the crime scene)—could be upheld given the close physical proximity of their residential addresses to the scene of the crime.
Whether the defense’s evidence fulfilled the strict requirements of time and location necessary to prove physical impossibility of the accused being at the scene.

Whether the trial court erred in giving full weight to the documentary evidence (photographs, autopsy report) and circumstantial evidence that supported the prosecution’s narrative despite the defense’s challenges.
Whether the trial court properly integrated the witness testimonies with the physical evidence in reaching its conclusion.