Case Digest (G.R. No. 193837)
Facts:
People of the Philippines v. Renato M. Pangan, G.R. No. 193837, September 21, 2016, Supreme Court Third Division, Perez, J., writing for the Court. The appeal arose from a conviction for robbery with homicide rendered by the Regional Trial Court (RTC), Branch 53, Guagua, Pampanga, affirmed by the Court of Appeals, Thirteenth Division, and reviewed by the Supreme Court under Rule 45.The Information (12 February 2004) charged Renato M. Pangan (appellant) with robbing and killing Rodolfo Ocampo on or about 21 August 2003 in Floridablanca, Pampanga, alleging the taking of the victim’s personal belongings (Php 17,060.00) and that the accused, armed with a bladed weapon, hacked the victim in the head and neck resulting in death. Appellant pleaded not guilty and trial proceeded.
Prosecution witnesses included Ernesto Aguinaldo, widow Carmencita Ocampo, Michael Aragon, Rialyn Napicog, SPO1 Rosby Ramos, Dr. Jude Doble (forensic pathologist), and Mauricio Magtoto. The defense admitted the sworn statements of Aguinaldo, Ocampo and Aragon in lieu of live testimony. Aguinaldo testified seeing appellant with the victim on 21 August; the victim’s decomposing body was discovered on 24 August. Aragon and Napicog indicated appellant had possessed a Nokia 3310 mobile phone bearing names associated with the victim. Napicog allegedly produced the phone for SPO1 Ramos; Ramos testified he kept custody of the phone until it was marked in court. Dr. Doble’s autopsy found death by hemorrhage and shock from hack wounds but gave no approximate time of death. Magtoto claimed appellant confessed, but no sworn statements from other alleged confessants were offered.
Appellant denied involvement, offered an alibi (at home with siblings on 21 August), denied giving Napicog any phone, and claimed coercion by SPO1 Ramos to confess. He was arrested on 26 August 2003.
On 8 April 2008 the RTC convicted appellant of robbery with homicide and sentenced him to reclusion perpetua, awarding civil damages. The Court of Appeals affirmed on ...(Subscriber-Only)
Issues:
- Did the prosecution prove beyond reasonable doubt the elements of the complex crime of robbery with homicide (the fact of robbery and that the homicide occurred on the occasion of or by reason of the robbery)?
- Were the circumstantial evidence and the presumption under Section 3(j), Rule 131 of the Revised Rules of Evidence sufficient to establish appellant’...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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