G.R. No. 228000 - People vs. Palema y Vargas

The case involves the People of the Philippines as the plaintiff-appellee and several accused-appellants, namely Ronald Palema y Vargas, Rufel Palmea y Bautista, Lyndon Saldua y Quezon, and Virgo Grengia.
Other individuals involved include minor Lester Ladra y Palema, Edwin Manzanero y Bautista, and Marvin Marqueses, whose participation varied during the incident and subsequent proceedings.

On November 10, 2007, at around 11:00 p.m., Enicasio Depante was seated at the Calamba Town Plaza along with his common-law spouse, his son Erickson Depante, and his stepdaughter Jamie Rose Baya.
Three men—later identified as Palema, Palmea, and Manzanero—approached Enicasio, culminating in a violent encounter.

Palmea threw a punch in an attempt to grab Enicasio’s cellphone.
Palema produced a knife and, after initially being warded off by Jamie, eventually stabbed Enicasio on the right thigh, causing him to collapse.

After the initial assault, Grengia and Saldua joined the fray by beating Enicasio.
Erickson, in an effort to aid his collapsing father, was impeded by Lester Ladra, who attempted to stab him when he resisted.
Enicasio was brought to Calamba Medical Center by Erickson but later died from blood loss.

An Information dated November 26, 2007, charged the accused with robbery with homicide, indicating that the purpose was to unlawfully seize the victim’s cellphone, and that the killing was incidental to the robbery.
During arraignment, most accused (including Ladra, Saldua, Palema, Palmea, Manzanero, and Grengia) pleaded not guilty, while Marvin Marqueses remained at large.
Pre-trial proceedings were conducted, followed by trial on the merits where the prosecution presented eyewitness testimonies and documentary evidence, including receipts for medical and funeral expenses incurred by the victim’s family.
Testimonies revealed:

The coordinated approach by the accused during the robbery.
The sequence of events wherein Palema and Palmea took the cellphone, and when Enicasio resisted, violence escalated culminating in his stabbing and beating.
The conflicting accounts regarding the precise nature and timing of the stabbing.

Minor Lester Ladra changed his plea to guilty and testified regarding the composition of the group, asserting that Grengia did not participate in the assault.
Edwin Manzanero died during the pendency of the case, and the trial court dismissed the case against him.
The Regional Trial Court rendered decisions:

In March 2012, convicting Ladra for robbery with homicide with a suspended sentence due to his minority status.
In April 2013, convicting Palema, Palmea, Saldua, and Grengia of robbery with homicide, while acquitting Marvin Marqueses for lack of evidence of participation.

The Court of Appeals, in its May 18, 2016 Decision, affirmed the Regional Trial Court ruling, giving due credit to the eyewitness testimonies and the evidence of conspiracy among the accused.
A Notice of Appeal was subsequently filed challenging both the conviction of the primary accused and the acquittal of Marvin Marqueses.

The prosecution established that the primary intent of the accused was to commit robbery, with the homicide occurring incidentally on the occasion or by reason thereof.
Evidence showed that the accused acted in unison on the night of the incident, despite their later claims of being present in different groups with unrelated persons.
The defense raised issues regarding:

Discrepancies in the location of the stab wound as pointed out by differing testimonies (witness account versus post-mortem examination findings).
The credibility of Erickson’s testimony, given that he was reportedly texting prior to the assault.
The existence of a conspiracy, contending that there was no unity of purpose.

The Regional Trial Court, supported by the Court of Appeals, dismissed these defenses, emphasizing that the coordinated actions and the admitted conspiracy in Ladra’s confession substantiated the prosecution’s case.

Marqueses was never properly arraigned; his name did not appear on the Certificate of Arraignment, and he was absent during pre-trial proceedings.
The absence of his arraignment raised significant due process concerns, leading to the eventual voiding of the acquittal granted on his behalf.

Whether the Court of Appeals erred in affirming the conviction of accused-appellants Ronald Palema, Rufel Palmea, Lyndon Saldua, and Virgo Grengia for the crime of robbery with homicide.
Whether the prosecution sufficiently proved that the offenders’ original intent was to commit robbery, with the homicide being an incidental outcome.

Whether the acquittal of Marvin Marqueses is proper given the absence of his proper arraignment and the ensuing procedural irregularities.
Whether the failure to formally notify Marqueses of the charge (through proper arraignment) renders all subsequent proceedings against him void.