G.R. No. 108733 - People vs. Parel y Tejamo

Leticia Perez was the owner of Le Mars Food House, a restaurant on the ground floor of a three-storey building at No. 871 G. Apacible Street, Ermita, Manila.
The building was arranged with the restaurant on the ground floor; the second floor housed the storeroom and quarters for several employees; and the third floor contained the private quarters and a comfort room for Leticia and her son Michael.
Prior to the incident, Leticia cohabited with family members and employees: her sister Marita Banaban (cashier on vacation on 4 March 1992) and Estrellita San Luis, the common-law wife of accused Renante Parel y Tejamo and supervisor at the restaurant.

Renante Parel had been working at Le Mars as a kitchen helper until his transfer in 1991, though he would regularly return to substitute when needed.
He maintained a close relationship with his live-in partner Estrellita, who was also employed at the restaurant as supervisor.
On the day of the crime, there was a normal assignment of duties among employees including Jean Santollo (countergirl), Mary Yurag (cashier), Luz, Samuel, and others who were seen performing routine tasks around the restaurant.

In the early afternoon, Leticia called her son Michael from Sucat, Paranaque, asking for assistance at the restaurant as her usual helpers were either absent or on leave.
Michael arrived around 1:00 PM, helped with the cash register operations, and later retrieved cash (notably P4,000.00 in 100-peso bills and additional smaller denominations totaling P2,000.00) to be placed in Leticia’s bag.
Employee movements and activities during the day were extensively noted:

At about 2:00 PM, Michael left to run an errand.
By 3:00 PM, Jean Santollo encountered Renante on the second floor while he was engaged in repacking bijon noodles with Luz and Samuel; Renante also interacted with other employees on different floors.
Witness Jean later observed Renante appearing by the stairway at around 4:30 PM and then, after a brief absence, reappearing in the kitchen.
Mary Yurag and other employees were seen performing their duties and conversing with Renante during the afternoon.

At approximately 8:00 PM, Michael returned to supervise the restaurant’s closing and discovered his mother’s body in her bedroom on the third floor. The autopsy later revealed death by asphyxia (strangulation) with a linear abrasion on her neck.

On the evening of 4 March 1992, Estrellita, Marita, and Renante were together at their residence and later rushed to the crime scene when notified by co-employees.
The investigation gathered evidence through testimonies of several employees and police officers, detailing the timeline of movements inside the restaurant as well as the discovery of Leticia’s body, her disordered room, and missing money.
On 6 March 1992, during police custody, Renante was held for questioning. He was alleged to have made statements confessing to the killing and robbery (divesting the victim of a sum totaling approximately P6,005.00) while inconsistent accounts and concerns regarding a forced confession emerged.
Renante alleged that on the date of the incident he was seen handling money delivered by his brother Danilo, a fact later corroborated by the claim that P6,000.00 had been transferred to him—of which half was purportedly for their mother in Bacolod and was later partly turned over to the police by Estrellita.
The police interviews noted irregularities including the alleged use of physical force when Renante refused to comply with certain procedures like fingerprinting and signing documents.

Critical witnesses such as Jean Santollo and Marita Banaban provided key testimony linking Renante’s presence at the restaurant with suspicious behavior (e.g., his sudden disappearance and reappearance).
The circumstantial nature of all evidence meant that no eyewitness testimony confirmed that Renante directly entered Leticia’s bedroom, took money, or committed the act of strangulation.
The defense maintained that mere presence at the scene or involvement in routine activities at the restaurant did not demonstrate an intention to rob or kill.
The alleged extrajudicial confession obtained during custodial investigation was disputed on grounds of constitutional infirmities, namely the failure to advise Renante of his rights to counsel and to remain silent as provided under the 1987 Constitution.

Whether the chain of circumstantial evidence presented by the prosecution constituted an unbroken, consistent series of events that could prove beyond reasonable doubt that Renante Parel y Tejamo committed the special complex crime of robbery with homicide.

The evidence relied solely on circumstantial circumstances.
The absence of eyewitness testimony linking Renante to the direct act of robbery or the act of strangulation itself.

Whether the extrajudicial confession allegedly made by Renante during custodial investigation was admissible in evidence.

The issue of whether Renante was informed of his constitutional rights, including the right to remain silent and to have competent counsel.
The adequacy of legal procedures followed during the interrogation, particularly regarding the waiver of these rights.

Whether there was sufficient evidence to show that the money missing from Leticia Perez’s bag was in fact the product of a robbery orchestrated by Renante.

The demonstration of intent to gain through the action of taking personal property belonging to another.
The prosecution’s failure to conclusively prove that Renante appropriated money that did not belong to him.