Case Digest (G.R. No. 141644) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Rolando Pineda y Manalo, G.R. No. 141644, decided May 27, 2004 under the 1987 Constitution, the Regional Trial Court of Caloocan City, Branch 127 found appellant Rolando Pineda guilty of Robbery with Homicide under Article 294(1) of the Revised Penal Code, as amended by R.A. 7659. The Information alleged that on October 15, 1997, in Caloocan City, Pineda and five other armed men boarded a Dreamline Aircon bus, threatened its driver and conductor with firearms, robbed approximately sixty passengers of cash and valuables, and shot SPO1 Arnel Fuensalida, who later died of multiple gunshot wounds. Pineda was arrested in September 1998 and pleaded not guilty at his May 24, 1999 arraignment. The prosecution presented the bus driver, conductor and police witnesses; the defense offered an alibi supported by contractor Lillian Tan, acquaintance Efren Quiton, and co-accused Victor Colet, whom the trial court eventually acquitted by Demurrer to Evidence. Th Case Digest (G.R. No. 141644) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Charge
- On 15 October 1997, in Caloocan City, Rolando Pineda y Manalo and five companions boarded an air-conditioned bus and, by means of firearms and intimidation, robbed the passengers and driver, culminating in the shooting and death of SPO1 Arnel Fuensalida.
- The passengers included bus driver Camilo Ferrer and conductor Jimmy Ramos, who later gave statements and trial testimony.
- An Information was filed on 21 April 1998 for “Highway Robbery Resulting in Homicide,” later recharacterized by the trial court as robbery with homicide under Article 294 of the Revised Penal Code.
- Procedural History
- Appellant Pineda was arrested on 5 September 1998 and arraigned on 24 May 1999, pleading not guilty. Co-accused Victor Colet was arraigned on 27 September 1999; the other accused remained at large.
- Trial commenced before RTC Branch 127, Caloocan City, where the prosecution and defense presented their evidence.
- On 21 January 2000, the trial court convicted Pineda of robbery with homicide, imposed the death penalty, and awarded civil indemnities; it acquitted Colet on Demurrer to Evidence.
- Prosecution’s Evidence
- Witnesses: widow Amalia Fuensalida, driver Ferrer, conductor Ramos, police officers Andaya and Susano, and medico-legal officer Dr. Freyra.
- Physical evidence: ocular inspection of the bus with recovery of slugs and shells; autopsy report detailing six gunshot wounds, contusion, and abrasion, concluding death by hemorrhage.
- Identification: Ferrer and Ramos testified to seeing the hold-uppers at close range; Ferrer identified Pineda through mug shots shown by police.
- Defense’s Evidence
- Appellant’s alibi: testified he worked from 8:00 a.m. to 5:00 p.m. on 15 October 1997, then went home and to a contractor’s house until 9:00 p.m.
- Corroboration: contractor Lillian Tan and acquaintance Efren Quiton confirmed his whereabouts; co-accused Colet, present on the bus, testified Pineda was not involved.
- Allegation of fabrication: appellant claimed police and co-accused Sison and Colet conspired to implicate him.
- Trial Court Decision
- Recharacterized the offense as robbery with homicide under RPC Art. 294 with the aggravating circumstance of band commission.
- Found Ferrer and Ramos “positive, spontaneous, and forthright,” rejected the alibi, and convicted Pineda; acquitted Colet on Demurrer to Evidence.
Issues:
- Whether the identity of appellant as one of the perpetrators was properly established beyond reasonable doubt.
- Whether the trial court erred in giving full probative weight to the testimonies of Ferrer and Ramos despite inconsistencies and suggestive identification procedures.
- Whether the court improperly discounted Colet’s testimony exculpating appellant.
- Whether the trial court wrongly rejected appellant’s defense of alibi.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)