Case Digest (G.R. No. 79138)
Facts:
On February 21, 1985, in Marikina, Metro-Manila, David S. Loveria y Santos, then aged 25 and a volunteer worker, boarded a Cubao–Cogeo passenger jeepney with three unknown accomplices. At around 7:00 p.m., one of the four announced a hold-up; Loveria, seated directly behind the driver, Cerilo Manzanero y Nacion, pressed a knife against Manzanero’s nape, pulled him to the rear of the jeepney, and inflicted stab wounds that would have been fatal but for prompt medical treatment. Simultaneously, another accomplice stabbed conductor Richard Bales y Andres, seizing his Seiko watch, while a third stabbed passenger Ricardo Yamson y Malanon, who later died of a neck wound. Police testimony, medical certificates, receipts for Manzanero’s hospitalization and Yamson’s funeral, and the victim-witness accounts formed the bulk of the evidence. The Regional Trial Court convicted Loveria of Robbery with Homicide and Frustrated Homicide (Art. 294[1], RPC), imposing reclusion perpetua and orderinCase Digest (G.R. No. 79138)
Facts:
- Charge and Arraignment
- On February 21, 1985, in Marikina, Metro Manila, David Loveria y Santos was charged with:
- Robbery with homicide (Art. 294[1], RPC) – killing of passenger Ricardo Yamson.
- Frustrated homicide – stabbing of jeepney driver Cerilo Manzanero prevented from causing death by timely medical care.
- Appellant pleaded not guilty upon arraignment on July 3, 1985.
- Commission of the Crime
- Around 7:00 PM, a fully loaded jeepney en route from Cubao to Cogeo was held up on the Barangay Baranca bridge.
- Accused and three John Does, armed with knives, forced driver Manzanero to stop, pulled him to the rear, stabbed him repeatedly, and robbed passengers of watches, rings and cash.
- Passenger Yamson was chased to the front, stabbed in the neck and died that night; conductor Bales was stabbed in the finger; Manzanero sustained multiple chest wounds but survived due to medical treatment.
- Trial Evidence
- Eyewitnesses: Manzanero, conductor Richard Bales, passenger Betty Apolinario – all positively identified appellant as one of the stabbers.
- Police testimony: Patrolmen Ayun and Agueda conducted investigation; ex‐parte affidavits (Exhs. I, O).
- Medical evidence: Dr. Ligot’s medico‐legal certificate (Exhs. A, A‐1) diagnosing bilateral hemothorax, thoracostomy.
- Civil damages: Receipts for Manzanero’s P8,221.80 medical expenses (Exhs. J–M) and Yamson’s funeral costs totalling P28,750.00.
- Defense and Trial Court Disposition
- Alibi: Appellant claimed attendance at a seminar (Feb 18–22, 1985) in Manila; met his father in Cubao at 8:30 PM on Feb 21.
- Trial court (May 26, 1987) found appellant guilty, imposed reclusion perpetua, and awarded indemnities:
- Yamson heirs – P30,000 indemnity; P10,000 actual; P10,000 moral; P10,000 exemplary.
- Manzanero – P8,221.80 actual; P5,000 moral; P5,000 exemplary.
- Bales – P300 for unrecovered watch.
Issues:
- Whether the trial court erred in crediting prosecution witnesses.
- Whether appellant’s right to counsel was violated during the identification at PC headquarters.
- Whether the alibi defense was sufficiently established.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)