G.R. No. 125053 - People vs. Leonor

The Regional Trial Court of ParaAaque, Branch 274, in Criminal Case No. 95-212, found accused-appellant Christopher CaAa Leonor guilty beyond reasonable doubt of robbery with homicide.
The trial court sentenced him to the penalty of death and ordered him to pay various monetary awards to the victim’s heirs, including death indemnity, actual damages, moral damages, and attorney’s fees.

On May 15, 1995, at around 11:30 a.m. in the Hermanos Building, located along General Santos Avenue, Bicutan Extension, ParaAaque City, the accused stabbed dentist Dr. Maria Teresa Tarlengco, which directly led to her death.
The sequence of events began when Dr. Tarlengco was attending to her dental practice. A man, later identified as Christopher Leonor, initially inquired about the cost of a tooth extraction, departed, and then returned in haste.
Upon his return, after negotiations regarding the dental fee broke down, Dr. Tarlengco was preparing for the procedure when the situation escalated with the accused demanding money, resulting in a violent altercation that led to the stabbing and the subsequent theft of cash and a Titus wristwatch.

Security guard Reynaldo Baquilod, who observed the incident and retrieved stolen items from the accused;
Police Officers SPO1 Luis Galeno and PO3 Mateo Interia, who apprehended the accused and documented incriminating evidence;
Medical experts and attending physicians, such as Dr. Ravell Ronald Baluyot, Dr. Edgardo de Guzman, Dr. Paul Pepa, and Dr. John Enrique Franco, who testified on the nature of the injury and provided details from the post-mortem examination.

The dying declaration of Dr. Tarlengco, delivered to her father in the operating room, was pivotal in establishing both the occurrence of a robbery and the fact that homicide was committed on its occasion.
Additional testimonies from relatives (Fernando and Geraldine Tarlengco) and Dr. Tarlengco’s fiancé, Joseph Sumalbar, further corroborated the events, including details of the robbery, the violence used, and the stealing of the victim’s personal belongings.

Christopher Leonor testified that he left his hometown early on May 15, 1995, with the intention of fetching his family for a town fiesta, carrying only P800 and a fan knife.
Upon reaching Bicutan Extension, he sought dental treatment for his aching teeth and encountered Dr. Tarlengco at her clinic. A disagreement over the extraction fee ensued, leading to an altercation where, according to him, he merely pushed aside Dr. Tarlengco’s hand after a verbal dispute.
He claimed that he did not intend to commit homicide nor did he plan to steal, insisting that he “did it because he needed money for his family” and contending that any admission made was taken out of context or under coercive circumstances.
The defense argued that the prosecution’s witnesses presented inconsistent and contradictory testimonies, alleging that key elements such as the retrieval of the stolen items were either omitted in early statements or later introduced, thereby questioning the reliability of the evidence.

After the stabbing, the accused was pursued by a security guard and later apprehended by police, during which he was physically overpowered, had his wallet and clothes confiscated, and was further beaten by law enforcement personnel.
Physical evidence, notably a bloodied fan knife (balisong), was recovered at the scene, corroborating the violent nature of the assault.
The documentation of financial losses incurred by the victim’s family—including hospital expenses, funeral costs, and other related expenditures—further substantiated the gravity of the offense.

Whether the evidence sufficiently establishes that the accused, in committing a robbery, also perpetrated homicide by means of violence and intimidation.
Whether the taking of personal property (cash and a wristwatch) from Dr. Tarlengco during the commission of a violent act constitutes the essential element of robbery with homicide.

Whether Dr. Tarlengco’s dying declaration, as narrated to her father, meets the requisites of admissibility despite being hearsay.
Whether the declaration, combined with corroborative evidence, firmly establishes the circumstances surrounding both the robbery and the homicide.

Whether the testimonies of prosecution witnesses (Baquilod, Galeno, Interia, Sumalbar, among others) are inherently superior to the accused’s version, given their in-court presentation.
Whether any inconsistencies in the early affidavits, notably concerning the recovery of stolen items, diminish the overall testimonial credibility of the witnesses.

Whether the defense’s claims of lack of intent, sufficient provocation, passion, obfuscation, voluntary surrender, and spontaneous confession qualify as mitigating circumstances.
Whether these proposed mitigating factors warrant a reduction of the charge from robbery with homicide to mere homicide or a lesser offense.

Whether the manner in which the accused’s admissions were obtained—without written documentation, representation, or warning of consequences—and later classified qualifies as inadmissible hearsay evidence.
Whether procedural deficiencies in the evidence gathering compromise the integrity and conclusiveness of the prosecution’s case.