Case Digest (G.R. No. 125539)
Facts:
In the case entitled People of the Philippines vs. Alfonso Patalin, Jr., Alex Mijaque, and Nestor Ras, G.R. No. 125539, decided on July 27, 1999, by the Supreme Court of the Philippines, the accused-appellants were charges in two separate criminal cases, Criminal Case No. 18376 for robbery with physical injuries, and Criminal Case No. 18305 for robbery with multiple rapes, occurring on August 11, 1984, in Lambunao, Iloilo. The first amended information indicated that Alfonso Patalin, Jr. and Alex Mijaque, together with unidentified accomplices, engaged in robbery armed with bladed weapons and inflicted serious physical harm on the victim, Reynaldo Aliman. They stole cash and several personal items valued at seven hundred pesos (₱700.00). The second amended information, also dated October 11, 1985, extended charges to Nestor Ras for having raped multiple female victims during the robbery. Throughout the trial, the prosecution relied on the testimonies of the victims and other wi
Case Digest (G.R. No. 125539)
Facts:
- Overview of the Incident and Consolidated Cases
- Two separate crimes committed on or about August 11, 1984 in the municipality of Lambunao, Iloilo:
- Robbery with physical injuries (Criminal Case No. 18376)
- Robbery in band with multiple rape (Criminal Case No. 18305)
- Consolidation of Criminal Cases
- Criminal Case No. 18376 (robbery with physical injuries) versus Criminal Case No. 18305 (robbery with multiple rape) was consolidated with a later additional docketing (Criminal Case No. 18835) concerning Nestor Ras.
- Subsequent motions led to the consolidation of evidence and charges against the accused-appellants.
- Charges and Allegations
- Robbery with Physical Injuries (Criminal Case No. 18376)
- Accused-appellants Alfonso Patalin, Jr. and Alex Mijaque, along with unidentified companions, were charged with:
- Conspiring to commit a robbery in the dwelling of Corazon Aliman with use of force, violence, and intimidation.
- Testimonies of the primary complainants (Corazon Aliman, Reynaldo Aliman, and Josephine Belesario) were instrumental in the positive identification of the accused.
- Robbery in Band with Multiple Rape (Criminal Case No. 18305)
- Accused-appellants Alfonso Patalin, Jr., Alex Mijaque, and Nestor Ras were charged with:
- Conspiring and executing a robbery in the dwelling of Jesusa Carcillar, involving the forcible taking of valuables (cash, ring, earrings, and a wristwatch) totaling P6,500.00.
- Detailed medical and forensic reports documented extensive physical and sexual injuries sustained by the victims.
- The presence of aggravating circumstances, such as the use of deadly weapons (bolos, knives, firearms), the nighttime setting, the victim’s domicile (implying abuse of confidence), and the formation of a band of conspirators, were underscored throughout the case record.
- Evidentiary Findings and Testimonies
- Prosecution Evidence
- Testimonies of victims were detailed, recounting the progression of events from forced entry to the commission of violent acts.
- Descriptions of injuries:
- Reynaldo Aliman sustained hack wounds on the forearm and neck, necessitating prolonged hospitalization and incurring medical expenses (P8,000.00).
- Positive identification of the accused-appellants by multiple victims and corroborative testimony by relatives and neighbors.
- Defense Arguments and Alibi Claims
- Accused-appellant Alfonso Patalin claimed that his inclusion as an offender was due to a third person’s allegation and maintained an alibi of being at home in Pandan, Lambunao, supported by corroborative testimony from his employer.
- Accused-appellant Alex Mijaque argued that his name was not initially mentioned in the sworn statement of Reynaldo Aliman and maintained that he was confined at a farm in Manduriao at the time of the incident.
- Accused-appellant Nestor Ras presented an alibi of being in Antique and denied clear identification, arguing that witness testimonies were inconsistent regarding his involvement.
- All defenses also posited that their arrests were allegedly effected without proper warrants.
- Procedural History and Sentencing Background
- The charge(s) were first filed via an Amended Information on October 11, 1985, with allegations both for robbery with physical injuries as well as robbery with multiple rape.
- Accused-appellants pleaded “not guilty” at arraignment on November 12, 1985.
- After trial on the merits, a joint judgment was rendered finding the accused guilty beyond reasonable doubt in both consolidated cases.
- Initial sentencing by the trial court:
- In Criminal Case No. 18376, sentenced to an indeterminate penalty of imprisonment (minimum: 10 years and 1 day; maximum: 17 years and 4 months) with corresponding civil indemnifications.
- In Criminal Case No. 18305, sentenced to the death penalty (later reduced to reclusion perpetua) plus indemnification awards for the victims.
- The case also raised the issue regarding the retroactive effect of the constitutional abolition of the death penalty and subsequent legislative actions.
Issues:
- Sufficiency and Credibility of the Evidence
- Whether the trial court properly relied on the affirmative and corroborated identification by the victims in convicting the accused.
- Whether inconsistencies and delays in the reporting of the crimes impaired the credibility of the victims’ testimonies.
- Assessment of the Defenses
- Whether the defenses of denial and alibi, including the claim of arrest without a warrant, were properly considered and refuted based on the evidence.
- Whether the alleged errors in attributing responsibility to each accused-appellant warranted reversal of their convictions.
- Retroactivity and the Death Penalty
- Whether the retroactive effect of the 1987 abolition of the death penalty, as provided by the Constitution, vested a benefit in the accused.
- Whether the subsequent reimposition of the death penalty by Republic Act No. 7659 could lawfully affect the accused whose crimes were committed before its enactment.
- Legal Implications of Conspiracy
- Whether the elements of conspiracy were sufficiently proven, requiring an assessment beyond direct evidence of collusion among the accused.
- Whether the identified aggravating circumstances (nighttime, dwelling, band) were properly applied to enhance the criminal liability of the accused.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)