G.R. No. 116326 - People vs. Lee

The case involves an appeal from a Regional Trial Court decision in Malolos, Bulacan, where the accused were charged with robbery with homicide.
The primary victim in the robbery was Belen Portugal-Legaspi, a private complainant engaged in the jewelry business.
The offense occurred during a routine travel between her residence in Saluysoy, Meycauayan, Bulacan, and her jewelry store in Quiapo, Manila.

At approximately 7:00 p.m., Belen Legaspi, accompanied by her salesgirl Flordeliza Francisco and her only son, Joselito Legaspi, boarded a green Ford Laser driven by Joselito.
Shortly after entering the Meycauayan exit of the North Expressway, the Ford Laser was rammed from behind by a white, old-model Toyota Corona sedan, which then swiftly overtook and blocked its path.
A group of armed men emerged from the Toyota: four alighted (three armed with handguns and one with a long firearm) while two remained inside their vehicle.

The assailants forced Joselito to back the car until it struck a concrete wall near a textile factory, rendering it stalled.
Upon the car’s stoppage, the armed men disembarked; one fired his handgun in rapid succession (first in the air, then on the ground, and finally at Joselito).
The assailants then invaded the car—one forced his way beside Belen while another commandeered the steering wheel, and the remaining two occupied the back seat.
The assailants drove the Ford Laser for approximately one kilometer to a dumpsite in front of a church under construction.
They stripped Belen Legaspi of her valuables, which included two bags of assorted jewelry valued at about ₱3,000,000 and cash amounting to ₱65,000, before fleeing in the Toyota Corona.

Joselito Legaspi, who was 21 years old, sustained a gunshot wound to the chest that penetrated both lungs and the heart, causing massive hemorrhage; he was later pronounced dead at the Nazareno Clinic.
Dr. Benito B. Caballero, the Municipal Health Officer of Bocaue, conducted the autopsy at 8:30 p.m., affirming the cause of death as shock due to extensive hemorrhage from the chest gunshot.
The Legaspi family incurred substantial expenses for the wake (₱60,000) and funeral services (₱20,000).

On April 20, 1990, Robert Lee, Edmundo Rivera, Igmedio del Mundo, Angelito Orosco, and Wilfredo Alcantara were charged by the Bulacan Provincial Prosecutor with robbery with homicide under Article 294 of the Revised Penal Code.
The Information detailed that the accused, during a conspiracy, used unlicensed firearms, force, and treachery to commit the robbery from which the homicide ensued.
Initial arraignments saw Robert Lee and Eduardo Rivera plead not guilty; Angelito Orosco was later arrested (May 17, 1990 for Lee and Rivera, and February 18, 1991 for Orosco) and also pleaded not guilty.
The Regional Trial Court, on April 22, 1993, found Robert Lee, Eduardo Rivera, and Angelito Orosco guilty as co-principals in the crime, sentencing each to reclusion perpetua and ordering the payment of substantial indemnity and damage awards.

Evidence – specifically the extrajudicial confessions of his co-accused – should have been excluded, as they were obtained following warrantless arrests.
The reliability of the eyewitness identifications, given issues of poor lighting and alleged inconsistencies in the accounts.
An overall error in convicting him.

The Solicitor General, on behalf of the prosecution, countered that the nature of a warrantless arrest differs from custodial investigation and maintained that the confessions were voluntary and properly obtained.
The factual testimony of Belen Portugal-Legaspi and Flordeliza Francisco played a crucial role in linking Orosco to the shooting of Joselito.

Whether the extrajudicial confessions of co-accused Robert Lee and Eduardo Rivera, taken allegedly during warrantless arrests, should have been excluded from evidence.
The distinction between the legality of a warrantless arrest versus the manner in which evidence (confessions) is obtained during a custodial investigation.

Whether the eyewitness identification by Belen Portugal-Legaspi, despite assertions of poor lighting and minor inconsistencies, was sufficiently reliable to identify Angelito Orosco as the shooter.
The impact of conflicting or minor discrepancies between the testimonies of Belen Legaspi and Flordeliza Francisco on the credibility and overall weight of the witness evidence.

Whether the cumulative evidence established beyond reasonable doubt that Angelito Orosco directly participated in the commission of the homicide by shooting Joselito Legaspi during the robbery.

The propriety of awarding specific amounts for indemnity, moral, exemplary, and wake/funeral expenses.
Whether the award for wake and funeral expenses was supported by adequate documentary evidence, and if not, what adjustments were warranted.

Assessing whether the minor inconsistencies in witness testimony detract from the overall narrative that implicated Orosco, thereby affecting the justness of his conviction.