Case Digest (G.R. No. L-3254)
Facts:
The case involves the People of the Philippines as the plaintiff against three defendants: Eugenio Nate (alias Oniong), Alejandro Aquino (alias Adoay, alias Ongot), and Pablo Lalaquil. The case revolved around a robbery in band with homicide that occurred at approximately 2:00 a.m. on January 26, 1949, in barrio Tuliao, Sta. Barbara, Pangasinan. The victims, Fructuoso Loresco and his wife, were disturbed in their sleep by barking dogs and, upon looking out, observed several men approaching their home. As the intruders attempted to force the door open using firearms, Loresco was shot in the breast and subsequently died from internal hemorrhage three hours later. The intruders made off with P70 in cash. Following the incident, local law enforcement began an investigation that led to the eventual arrest of the defendants. A crucial piece of evidence was a school notebook with Alejandro Aquino's name found in the victim's yard, which subsequently implicated him and his accom
Case Digest (G.R. No. L-3254)
Facts:
- On the early morning of January 26, 1949, at about two o'clock, a robbery in band with homicide took place in barrio Tuliao, municipality of Sta. Barbara, Province of Pangasinan.
- Fructuoso Loresco and his wife were awakened by the barking of dogs. On looking out the window, they observed several men on the ground and two on or climbing the porch.
- As the intruders began forcefully shoving the door—secured only with a frail wire—Loresco attempted to bar it by holding it with his hands.
- The intruders discharged a volley through the door, striking Loresco in the breast and knocking him down, after which the door yielded.
- At gunpoint, the wife was forced to surrender the family cash amounting to P70.
- Fructuoso Loresco subsequently succumbed to internal hemorrhage three hours later.
Incident and Crime Details
- The constabulary initiated an investigation after the robbery and homicide, focusing on evidence found at the crime scene.
- Corporal Latornas discovered a school notebook in Loresco’s yard on which the name "Alejandro Aquino" was written, which became critical to the investigation.
- Aquino was arrested; his apprehension led to further detentions, including those of Pablo Lalaquil and Eugenio Nate.
- At the constabulary headquarters, Alejandro Aquino made a written confession in the presence of Sergeant Andaya—naming Lalaquil and Nate among his alleged accomplices.
Investigation and Arrest
- Pablo Lalaquil claimed he was at home during the incident, denying any involvement or prior knowledge of Fructuoso Loresco’s widow.
- Eugenio Nate testified that he was engaged as a special night guard at a distillery in Mangaldan during the time of the crime.
- Alejandro Aquino asserted that he was confined at home in Mangaldan due to an injury sustained on January 14, dismissing any participation and alleging that his confession was coerced under torture by the constabulary.
Defendant’s Alibis and Testimonies
- Identification of suspects was achieved through key eyewitness accounts:
- Benavidez Garcia, Loresco’s widow, identified Aquino and Lalaquil by examining them with a kerosene lamp—described as eight inches high with a tank of eight centimeters in diameter.
- Epifania Garcia (sister of Loresco’s wife) and her son Ceferino de Leon also provided positive identifications, particularly asserting that Aquino and Lalaquil were the intruders seen during the crime.
- Physical evidence supporting Aquino's connection to the crime included:
- The school notebook with his name found near the crime scene.
- A fresh, bleeding wound on his left hand, consistent with a gunshot injury, which he was seen nursing at the time of his arrest.
- Aquino’s confession, written in his own dialect and containing numerous details undisputed by the constabulary, recounted:
- An account of being approached by men in a jeep near barrio Banaoag who searched him for money.
- His compelled entry into the vehicle and subsequent journey with identified accomplices, including Nate and Lalaquil.
- Details regarding the sequence of events leading from the robbery at Loresco’s house to further actions at another residence.
- A recitation of hearing several shots and learning later of a fatality, along with a threat from Nate warning him against disclosing what he had witnessed.
Evidence from Identifications and Physical Clues
- Testimonies by eyewitnesses were pivotal in identifying Eugenio Nate:
- Benavidez Garcia provided a fleeting glimpse of Nate when she held the lamp, noting his facial features.
- Epifania Garcia confirmed observing Nate, including an incident where he allegedly pointed a gun at her, warning her not to come downstairs.
- Despite Nate’s claim of being employed and stationed in Mangaldan, the trial court found evidence sufficient to refute his alibi, noting that his work schedule and proximity did not preclude his being in Sta. Barbara during the early hours.
Testimonies Regarding Defendant Behavior and Credibility
Issue:
- The central issue was the accurate identification of the perpetrators involved in the robbery in band with homicide.
- The conflicting alibis of the defendants—each asserting innocence via established whereabouts—and the reliance on eyewitness identifications and physical evidence were examined to determine their actual participation.
Identity of the Malefactors
- The admissibility and authenticity of Alejandro Aquino’s confession, including whether it was voluntarily executed or obtained under duress, was scrutinized.
- There was a need to reconcile the evidence proffered by the eyewitnesses with the defendants’ claims and the physical evidence (i.e., the notebook and the gunshot wound).
Credibility of the Confession and Evidence
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)