G.R. No. 218628 - Evergreen Manufacturing Corp. vs. Republic

On the night of February 28, 1996, at approximately 7:00 p.m., Lydia Cuenca was driving her Tamaraw FX along Commonwealth Avenue, Quezon City.
Manuel Cuenca, the victim’s husband, was immediately behind her in his own vehicle with his employee, Larry Buseron, as a passenger.
During their homeward convoy, Lydia stopped at the corner of Don Enrique Subdivision and Commonwealth Avenue to execute a U-turn.
At that juncture, three armed men approached Lydia’s vehicle; initial efforts involved banging on the door to force it open.

When the initial attempt to open the door failed, one of the men shot the vehicle’s window, striking Lydia’s left shoulder.
A simultaneous shot from another man hit Manuel’s car.
After an unsuccessful attempt, one of the assailants broke the right door window using the butt of a gun.
The perpetrators eventually boarded the vehicle after repeated attempts, and further shots were heard including one that hit Lydia’s nape.
The entire sequence of the hold-up lasted approximately five to ten minutes.

Manuel attempted to pursue the fleeing vehicle but experienced a breakdown of his car.
Manuel instructed Larry Buseron to seek help from their store while he himself ran to a nearby store about 100 meters away.
Larry, unable to exit his locked car, later proceeded on foot to the police station when he found no assistance at the store.
A call from a concerned citizen initiated the police response; Police Station 6 was informed and dispatched several officers to the scene.

The police, led by SPO Bernarte and his team (including SPO4 Raul Espejon, SPO1 Ricardo Inamac, SPO2 Faustino, and SPO1 Diaz), arrived at the scene and attended to Lydia, who was found lying near the vehicle.
Lydia was transported to Fairview Hospital, where she was later declared dead, having sustained fatal gunshot wounds.
At a nearby compound (the Trans-World Compound), a security guard and barangay commando identified the suspects, leading to an ensuing gunfight between the police and the armed men.
During the shootout, one suspect known as “Baeng” was hit and later died, while the remaining suspects, including those later identified as Edgardo Liad and Jun Valderama, surrendered.
Evidence recovered included firearms (caliber .38 paltik revolvers), the victim’s jewelry and wallet (with the bag wedged in a banana plant), and other personal items.

Dr. Alvin David, the NBI’s Medico-Legal Officer, concluded via Autopsy Report No. N-96-42 that Lydia’s death was caused by two fatal gunshot wounds (one at the posterior chest and another at the left arm featuring muzzle tattooing).
A ballistic examination by Elmer Nelson Piedad (Report No. FID-123-92-29-96) established that one bullet, marked “LD-1”, was deformed and fired through a caliber .38 firearm with right-twisting riflings, while the second bullet (“LD-2”) was similarly caliber .38 but too deformed for a definitive firearm identification.

Accused-appellants Edgardo Liad and Jun Valderama were charged before the Regional Trial Court of Quezon City with Robbery with Homicide under Article 293 of the Revised Penal Code (in relation to Article 294) and with Illegal Possession of Firearm under Section 1 of Presidential Decree No. 1866 as amended.
The criminal information detailed their alleged participation in a conspiracy to commit the crime, including shooting the vehicle, boarding it, abducting Lydia, and robbing her of cash and valuables totaling over P185,090.00.
During arraignment, both accused-appellants pleaded not guilty.
Testimonies were presented from multiple witnesses including Manuel Cuenca, various police officers (SPO4 Espejon, SPO1 Inamac), Larry Buseron, and forensic experts.
The accused provided divergent accounts:

Jun Valderama claimed he was vending near Batasan Hills at the time and was later apprehended after a police frisk, during which a fan knife (which he asserted was for self-defense) was recovered.
Edgardo Liad admitted his presence at the scene but contended that his involvement was minimal and that he was essentially forced to cooperate under threat by co-accused Quintoa.

The victim’s son, Manuel Jr., and other circumstantial evidence were also presented to demonstrate the civil liability of the accused.

On March 2, 1998, the RTC rendered a decision convicting the accused for robbery with homicide and illegal possession of firearm.
The sentence imposed included reclusion perpetua for robbery with homicide, indemnity and damages payable to the victim’s heirs, and a prison term for illegal possession of firearm.
The trial court’s decision was later modified on appeal, particularly altering the computation of funeral and burial expenses and acquitting the accused for the offense of illegal possession of firearm.

Whether the evidence was sufficient to establish that the accused, namely Liad and Valderama, were participants in a conspiracy to commit robbery with homicide.
Whether the testimony of eyewitnesses, specifically that of Manuel Cuenca, was reliable enough to impute the acts of the conspirators to all accused.

Whether the trial court erred in convicting the accused-appellants for illegal possession of firearm despite the evidence not conclusively proving that they lacked the requisite license or permit.
The appropriate interpretation of existing jurisprudence concerning “paltik” (homemade guns), particularly in light of precedents such as People vs. Ramos and People vs. Fajardo.

Whether the trial court properly assessed and computed the indemnity, moral damages, and funeral expenses owed to the victim’s heirs based on the evidence presented.