Case Digest (G.R. No. 141699)
Facts:
People of the Philippines v. Wilfredo Layug, Noel Buan and Reynaldo Langit, G.R. No. 223679, September 27, 2017, the Supreme Court Second Division, Peralta, J., writing for the Court.The prosecution (the People of the Philippines) charged appellants Wilfredo Layug and Noel Buan, together with co-accused Reynaldo Langit, with robbery with homicide for the stabbing and robbery of Victorino Paule on June 1, 2001 in Dinalupihan, Bataan. The information alleged that the accused, acting in conspiracy and with intent to gain and to kill, stabbed Victorino multiple times and took his wallet, wristwatch and necklace, resulting in his death.
At trial the People presented eyewitness testimony by Analiza L. Paule (a state witness) and Ramil Ambrosio, and the medico-legal report of Dr. Roberto Castaneda showing 19 stab wounds and death from massive hemorrhage. Analiza narrated that after a shabu session she accompanied Victorino, boarded a tricycle with driver Jesus Ronquillo, returned to the plaza, then went with Victorino to the house of Wilfredo where appellants and Reynaldo were. Later they all rode a tricycle; upon reaching a secluded spot, Noel allegedly stopped the tricycle, caused Victorino to alight, then stabbed him while Wilfredo and Reynaldo joined in the stabbing and took Victorino’s valuables. Analiza and the tricycle driver remained in the vehicle from fear; Analiza later reported the incident.
The accused denied participation. Noel claimed an alibi implicating another man, Boy Timog, who allegedly stabbed Victorino; Wilfredo likewise denied involvement. The Regional Trial Court (RTC), Branch 5, Dinalupihan, Bataan, found all three guilty of robbery with homicide and sentenced them to reclusion perpetua (the RTC said treachery, evident premeditation and taking advantage of superior strength attended the crime, but applied reclusion perpetua in light of R.A. No. 9346). The RTC also ordered civil indemnity and temperate damages.
On appeal the Court of Appeals (CA) in CA-G.R. CR-HC No. 03500 (Decision dated April 23, 2015, penned by Justice Ramon A. Cruz) affirmed with modification as to Wilfredo and Noel: it found them guilty beyond reasonable doubt of robbery with homicide aggravated by treachery and evident premeditation (finding abuse of superior strength absorbed by treachery), imposed reclusion perpetua, and increased damages (P100,000 civil indemnity, P100,000 moral damages, P50,000 temperate damages, plus 6% interest). Reynaldo withdrew his appeal from the CA, so the RTC decision as to him stood.
The present appeal reached the Supreme Court for review of the CA decision....(Subscriber-Only)
Issues:
- Did the prosecution prove the guilt of appellants Wilfredo Layug and Noel Buan beyond reasonable doubt for robbery with homicide?
- Were the aggravating circumstances of treachery, evident premeditation, and abuse of superior strength properly appreciated in this case?
- Are exemplary damages warranted in favor of...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)