Case Digest (G.R. No. 90626)
Facts:
People of the Philippines v. Ricardo Alcoriza Lascuna, Rosita Dionisio Villena, Celso Cano Algoba and Placido Aquino Palangoy, G.R. No. 90626, August 18, 1993, Supreme Court First Division, Davide, Jr., J., writing for the Court.The case arose from an Information filed on January 16, 1989 in the Regional Trial Court (RTC) of Malolos, Bulacan charging four respondents — Ricardo Alcoriza Lascuna, Rosita Dionisio Villena, Celso Cano Algoba and Placido Aquino Palangoy (and implicating Danilo Lagasca, still at large) — with robbery with homicide, rape and physical injuries for events occurring on October 16, 1988 at the house of Luisa A. Villena. All four pleaded not guilty at arraignment on February 1, 1989. The trial court later directed that Danilo Lagasca be included as co-accused, though a separate information against Lagasca was also filed.
During trial, after the principal prosecution witness (Luisa Villena) completed direct examination on March 17, 1989, accused Lascuna and Algoba sought and were permitted to change their pleas to guilty; the RTC sentenced them to 12 years and one day to 20 years. Trial then proceeded against Rosita Villena and Placido Palangoy. The prosecution presented Luisa Villena, INP patrolmen, physicians who examined the victims, and a neighbor. The defense presented testimony from Celso Algoba (then serving sentence), Rosita Villena and Placido Palangoy; Lascuna was subpoenaed but did not appear.
Prosecution evidence established that Luisa and her brother Honesto were in the house when Rosita arrived with her child and four strangers, three of whom Luisa later identified as Algoba, Lascuna and Palangoy; the fourth was Lagasca. The intruders gagged and bound Luisa and Honesto, ransacked the house and took items worth P4,900.00; Lascuna raped Luisa and Lascuna and Lagasca strangled Honesto to death. Luisa regained consciousness, found her brother dead and later identified the apprehended suspects at the police station; items of clothing taken from the house were found on Palangoy when arrested. Autopsy and medical examinations corroborated strangulation of Honesto and abrasions on Luisa.
On August 21, 1989, after both sides rested, the RTC orally pronounced judgment finding Rosita Villena and Placido Palangoy guilty and sentencing each to reclusion perpetua and to indemnify Honesto’s family P30,000.00. A written ten‑page judgment dated August 21, 1989 containing findings and a signed dispositive was later issued. Rosita and Placido filed notices of appeal on August 23, 1989; Rosita later moved to withdraw her appeal, which this Court granted. The record was erroneously transmitted to the Court of Appeals and then forwarded to the Supreme Court; the Court accepted the appeal on May 29, 1991. The appeal thus concerns only appellant Placido Aquino Palangoy.
Appellant raised multiple assignments of error on appeal: that the RTC relied improperly on alleged admissions, erred in c...(Subscriber-Only)
Issues:
- Was appellant Placido Palangoy denied procedural due process by the trial judge’s conduct and the verbal promulgation of judgment?
- Was the evidence — particularly Luisa Villena’s identification and appellant’s possession of stolen clothing — sufficient to convict appellant beyond reasonable doubt?
- Was rape against Luisa Villena proven beyond reasonable doubt?
- Were the homicide and rape attributable to appellant as principal in the special complex crime of robbery with homicide aggravated by rape, notwithstanding alleged lack of direct participation?
- Should the mitigating circumstances under Article 13, par. 3 or 10 of the Revised Penal Code have been applied, and did the sentencing of co‑accused affect appellant’s liability or penalty?
- Were the awards of actu...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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