Case Digest (G.R. No. 52119)
Facts:
People of the Philippines v. Benjamin Padilla, G.R. No. 52119, April 24, 1989, Supreme Court First Division, Gancayco, J., writing for the Court.The prosecution arose from the May 6, 1976 killing and robbery of spouses Crisostomo Amarillo and Anita Galamgam, small-time gold buyers from San Felipe, San Nicolas, Pangasinan. At about 5:30 p.m. the couple, carrying roughly P40,000 in cash and jewelry, were followed and accosted by three men identified at trial as Mateo Padilla, Boy Batin, and Benjamin Padilla. Mateo hacked Crisostomo with a bolo; Crisostomo fell after suffering multiple blows and bleeding. Anita attempted to flee but was pursued and struck repeatedly by Batin. Both victims died from multiple sharp-edged wounds and massive hemorrhage confirmed by autopsy.
A bystander, Francisco Doton, who had been cutting cogon grass nearby, was ordered by Mateo to take one of the bags containing money and to cover the blood with sand. Doton complied, later deposited P9,000 in a bank in Urdaneta (having taken that amount from the red bag), and discarded the empty bag. The police investigation led to an information for robbery with double homicide filed in the Court of First Instance of Pangasinan against Mateo, Benjamin, Francisco and Boy Batin; Boy Batin remained at large while the others were arrested. At the start of trial, Doton was discharged as a government (state) witness.
On September 25, 1979 the trial court convicted Mateo Padilla and Benjamin Padilla of robbery with double homicide and sentenced each to reclusion perpetua, ordered joint and several indemnity to the heirs in the aggregate amount of P32,740 (noting a recovery of P9,000), and confiscated the bolo used by Mateo. Mateo did not appeal and commenced serving his sentence; only Benjamin Padilla appealed to the Supreme Court, challenging (1) the trial court’s reliance on the testimony of d...(Subscriber-Only)
Issues:
- Was it proper for the trial court to convict appellant based substantially on the testimony of a discharged co-accused who had become a state witness?
- Was the evidence, including the eyewitness identification and the asserted alibi and contradictions, sufficient to sustain conviction be...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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