Case Digest (G.R. No. 106210-11)
Facts:
People of the Philippines v. Roberto Rambo Lising, Rodolfo Manalili, Felimon Garcia, Enrico Dizon and Robin Manga, G.R. Nos. 106210-11, January 30, 1998, First Division, Kapunan, J., writing for the Court. The plaintiff-appellee was the People of the Philippines; the appellants/accused were Roberto Rambo Lising, Rodolfo Manalili, Felimon Garcia, Enrico Dizon and Robin Manga (Ligaya Fausto was separately charged as accessory but was acquitted by the trial court).In March–April 1990 Manalili sought persons to effect the arrest of a suspect, Robert Herrera. Garcia introduced Manalili to Lising (a policeman) and others; an agreement for a P50,000 consideration was made and P2,000 advanced. On April 25, 1990 the group followed a green Lancer that carried Ernesto “Cochise” Bernabe II and Ana Lourdes “Beebom” Castanos. Two men identifying themselves as policemen forcibly handcuffed and placed the couple in cars; the victims were brought to a Valle Verde motel and later to a warehouse in San Fernando, Pampanga.
Awarehouse employee, Raul Morales, later told investigators that he saw Cochise and Beebom brought into the bodega and that Cochise was stabbed and buried in a shallow grave; both victims’ bodies were exhumed in late June 1990 and autopsies showed multiple stab wounds. After a manhunt, Lising, Garcia and others gave extrajudicial statements; arrests and surrenders followed (Lising apprehended June 30, 1990; Garcia surrendered January 4, 1991; others were taken into custody thereafter).
Two criminal informations (carnapping and kidnapping with double murder) were filed. At trial the prosecution relied chiefly on eyewitnesses Froilan Olimpia (who saw the abduction at Timog Circle) and Raul Morales (who witnessed events at the bodega), plus the extrajudicial/confessional statements of several accused. The accused mounted alibi and other defenses; some (Manalili, Garcia) did not testify but had earlier executed extrajudicial statements.
The trial court (decision dated July 1, 1992) convicted Lising, Manalili, Garcia, Manga and Dizon of double murder with qualifying circumstances and sentenced them to double reclusion perpetua, awarded civil damages, acquitted Ligaya Fausto, and acquitted all accused ...(Subscriber-Only)
Issues:
- Were the extrajudicial (sworn) statements of the accused admissible against co-accused and admissible as corroborative or interlocking confessions?
- Did the trial court rightly credit the testimony of eyewitnesses Froilan Olimpia and Raul Morales as sufficient to sustain conviction?
- Was there sufficient proof of conspiracy such that each accused could be held criminally liable for double murder, and were the sentences for relate...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)