Case Digest (G.R. No. L-37750)
Facts:
This case, known as People of the Philippines vs. Vicente Pajanustan, revolves around a horrific incident of robbery with homicide that occurred on December 1, 1970, in the house of spouses Jesusimo Aco, aged 70, and Simeona Aco, aged 63, located in Sitio Cabalocawe-an, Barrio Quezon, Las Navas, Northern Samar. The Aco couple, along with their grandsons Rodolfo Lucapa, 14, and Jose Ultra (Lucapa), 9, were murdered in their sleep. The assailants stole various items from the house, including coins worth ₱250, a necklace valued at ₱120, a ring worth ₱150, a gold button worth ₱50, and clothing totaling ₱720. The victims suffered multiple stab wounds, with Jesusimo having four, Simeona 23, Rodolfo 17, and Jose 9. Vicente Pajanustan, aged 45, a farmer from Sitio Pagdadalitan, Barrio San Miguel of Las Navas, was identified as one of the assailants during the investigation. He and two unidentified companions had been guests at the Acos’ home the night of the incident. After initially ev...Case Digest (G.R. No. L-37750)
Facts:
- Overview of the Case
- The case involves a charge of robbery with homicide committed on the evening of December 1, 1970.
- The victims were the elderly couple Jesusimo Aco (70) and Simeona Subia (63), along with their two grandsons, Rodolfo Lucapa (14) and Jose Ultra (9).
- The crime occurred in the home of the victims located at Sitio Cabalocawe-an, Barrio Quezon, Las Navas, Northern Samar.
- Details of the Crime
- During the incident, the perpetrators committed robbery:
- They stole coins amounting to ₱250.
- They took a necklace valued at ₱120.
- A ring worth ₱150 was taken.
- Other items included a gold button (₱50), two new pants (₱50), two polo shirts (₱40), and two additional shirts (₱60).
- The total value of the objects robbed was ₱720.
- The assailants’ violent actions resulted in multiple stab and incised wounds on all victims:
- Jesusimo Aco suffered four wounds, including a fatal stab wound to the abdomen that perforated his small intestine and two neck stab wounds severing vital arteries.
- Simeona Subia sustained twenty-three wounds, several of which compromised her lungs, heart, and carotid artery.
- Rodolfo Lucapa was found with seventeen wounds affecting vital organs like the lungs, kidney, and small intestines.
- Jose Ultra received nine stab wounds, some injuring his carotid artery.
- Position and Statements of the Accused
- Vicente Pajanustan, a 45-year-old farmer residing at Sitio Pagdadalitan, Barrio San Miguel, Las Navas, was identified as being present at the scene, along with two companions.
- At the time of the incident, Pajanustan and his two companions were fed and lodged in the victims’ house.
- During the preliminary investigation, Pajanustan:
- Pleaded guilty to charges but shifted blame by stating that his companions—identified as Nori Magtolis and Quirico Pajares—committed the murders.
- Claimed he did not actively participate in the killing and left the premises when the murders commenced.
- Admitted to having a previous criminal charge for frustrated murder linked to an assault on Remegio Panco in 1969.
- The fiscal later filed a second amended information on December 8, 1971, now charging Vicente Pajanustan alongside his first cousin, Domingo Pajanustan, with robbery with multiple homicide.
- At trial:
- Vicente reiterated his version of events, contending he attempted to dissuade Magtolis from stabbing Jesusimo Aco.
- The trial court acquitted Domingo Pajanustan but convicted Vicente on the charges of robbery with homicide, aggravated by treachery and abuse of confidence (through the absorption of dwelling).
- Circumstantial Evidence and Witness Testimony
- Prosecution witness Julio Nungay, a farmer residing approximately 150 meters from the crime scene, testified:
- He encountered Vicente Pajanustan and his two companions near the house while checking on his fishing hooks.
- Upon noticing a bloodstain on Pajanustan’s shirt, Nungay inquired about its origin.
- Pajanustan’s confused behavior, evidenced by his inability to correctly indicate the trail to Sitio Bay-ang—despite being familiar with the locale—suggested nervousness and guilt.
- Additional circumstantial factors included:
- Pajanustan’s delay in reporting the crime to the authorities.
- His escape and eight-month period in hiding.
- His established criminal record, which further cast doubt on his claims of non-involvement.
Issues:
- Whether the circumstantial evidence presented was sufficient to establish beyond reasonable doubt that:
- Vicente Pajanustan was an active co-conspirator and co-principal in the commission of the robbery with homicide.
- The evidence conclusively refuted his claim of non-participation in the murders committed by his companions.
- Whether the aggravating circumstances of treachery and abuse of confidence were properly attended to in imposing the death penalty.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)