Case Digest (G.R. No. 116734)
Facts:
In People of the Philippines vs. Larry Laurente y Bejasa (G.R. No. 116734, March 29, 1996), the Regional Trial Court of Pasig, Branch 156, convicted defendant-appellant Larry Laurente of Highway Robbery with Homicide under Presidential Decree No. 532 after finding that on February 14, 1994 in Pasig City he, together with two companions, forcibly entered a taxicab, strangled and bludgeoned the driver to death and seized his daily earnings. Investigators recovered a wallet containing Laurente’s SSS ID from the vehicle and, based on that identification, arrested him the following day without a warrant. At trial the prosecution presented an eyewitness who positively identified Laurente, police testimony on the investigation and autopsy results; Laurente invoked alibi and challenged the identification, claiming his ID had been stolen. The trial court gave full credence to the eyewitness and Laurente’s admission, dismissed his alibi, imposed the death penalty, civil indemnities and daCase Digest (G.R. No. 116734)
Facts:
- Procedural History
- The RTC of Pasig (Branch 156) found Larry Laurente y Bejasa guilty beyond reasonable doubt of Highway Robbery with Homicide under P.D. No. 532 and imposed:
- Death penalty
- Indemnity to heirs: ₱50,000
- Funeral expenses: ₱27,300
- Moral/exemplary damages: ₱100,000
- Automatic review by the Supreme Court under Art. 47, RPC as amended by R.A. No. 7659.
- Incident Circumstances
- On 14 February 1994, victim Herminiano G. Artana was found dead in his parked taxi along F. Concepcion St., Pasig.
- Cause of death: strangulation by leather belt plus blunt‐force head injuries.
- Autopsy (Dr. Arañas) confirmed subdural/subarachnoid hemorrhages, peri‐orbital hematoma, neck contusion.
- Investigative findings:
- Eyewitness Myra Guinto saw three men scramble out of the taxi and flee; a fourth called police.
- A brown wallet containing Laurente’s SSS ID and the leather belt were recovered inside.
- Police “follow-up” arrested Laurente the next day; he allegedly admitted participation and was identified in a line-up.
- Victim’s daughter testified to funeral expenses (₱27,300) and that her father was a taxi driver.
- Defense
- Alibi: Laurente claimed he was intoxicated at home from ~3:30 p.m. to 4 a.m., unconscious and wallet lost thereafter; he worked 6 a.m.–8 p.m. on 15 Feb 1994.
- Custodial issues: arrest without warrant based solely on ID card; interrogation without counsel; admission not reduced to writing.
Issues:
- Application of P.D. No. 532 and death penalty
- Does P.D. 532 cover a robbery against a predetermined victim?
- Did R.A. No. 7659 validly restore the death penalty for P.D. 532 offenses?
- Sufficiency and admissibility of evidence
- Reliability of eyewitness identification (Myra Guinto).
- Proof of the robbery element (asportation, victim’s earnings).
- Lawfulness of arrest and admissibility of the alleged confession.
- Defense of alibi and penalty imposition
- Was alibi sufficiently proven?
- Appropriate penalty given constitutional and statutory constraints.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)