Case Digest (G.R. No. 109775)
Facts:
People of the Philippines v. Jose Encarnacion Malimit alias Manolo, G.R. No. 109775, November 14, 1996, the Supreme Court Third Division, Francisco, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the accused-appellant is Jose Encarnacion Malimit (alias Manolo).On April 15, 1991 at about 8:00 p.m., Onofre Malaki was attending to his store when he was discovered mortally wounded and his wallet missing. Two eyewitnesses, Edilberto Batin (Malaki’s houseboy) and Florencio Rondon (a farmer who lived some 150 meters away), testified that they saw the appellant rush out of Malaki’s store carrying a blood-stained bolo seconds before they discovered the victim. They reported the incident to Eutiquio Beloy (Malaki’s brother-in-law) and to the local CAFGU detachment, and Batin later made a similar statement at the Silago Police Station. The wallet and its contents (exhibits: wallet A; residence certificate A‑1; ID A‑2; keys A‑3) were later recovered.
The appellant was criminally charged by information dated November 28, 1991 with the special complex crime of robbery with homicide (Article 294(1), Revised Penal Code). At trial before the Regional Trial Court, Southern Leyte, Branch 26, the prosecution presented eyewitness testimony, medical evidence that Malaki died of multiple stab wounds, and testimony (Elmer Ladica) that on August 6, 1991 he saw the appellant retrieve Malaki’s wallet beneath a stone at the seashore in Barangay Hingatungan. The appellant admitted at trial that on August 6, 1991 he accompanied policemen to the seashore where he hid the wallet; he claimed an alibi for the night of the killing but did not present corroborating witnesses.
The trial court rendered judgment dated January 18, 1993 convicting Malimit of robbery with homicide and sentencing him to reclusion perpetua, ordering indemnity to the heirs in the amount of P50,000.00 without subsidiary imprisonment in case of insolvency, and costs. On appeal to the Supreme Court (the appealed judgment), the appellant raised three assignments of error: (1) alleged unreliability of eyewitness identification due to delay in disclosing the appellant’s identity; (2) alleged constitutional violation in the production of the wallet and ...(Pro-only)
Issues:
- Was the identification testimony of prosecution witnesses rendered unreliable by their alleged delay in identifying the appellant?
- Should Malaki’s wallet and its contents have been excluded as evidence because they were produced after custodial interrogation without the appellant being informed of his constitutional rights?
- Was the evidence presented by the prosecution insufficient to sustain a co...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)