G.R. No. 43588 - People vs. Luague

On July 29, 1986, in the municipality of Valenzuela, Metro Manila, a drinking session was held at the residence of Ricardo Rivera, also known as Carding Rivera.
The appellant, Lawrence Ponciano y Sabolan, together with companions and the victims, engaged in a drinking session that later turned violent.
During the gathering, a robbery and multiple killings occurred, resulting in the deaths of Ricardo Rivera, Alicia Rivera, and Regina Villanueva.

The information charged that the appellant, while armed with a bladed instrument (a kitchen knife), committed felonious acts including robbery and stabbing.
The accused allegedly stole articles, notably one Sony Betamax set with remote control, a transformer, a rewinder, and two wristwatches, from the residence.
Testimonies and evidence later established that the appellant was caught in possession of the wristwatches and remote control, linking him directly to the theft.

The presence of the accused at the scene during the incident.
Observations of the accused holding a knife, with indications that he had blood on his clothing.

She saw the appellant brandishing a knife at her and Alicia Rivera, and later observed the victims’ disarray inside the house.
Her testimony linked the accused to the immediate threat and subsequent stabbing.

Other testimonies (from Orlando Silvestre, Pat. Orig, and additional witnesses) corroborated:

The presence of the accused at the scene.
Direct observations of the accused with a knife and evidence of bloodstains, as well as the recovery of stolen items.

The cause of death for each victim, all consistent with multiple stab wounds inflicted with the same bladed weapon.
The identification of the knife as the murder weapon.

He was intoxicated and under the influence of drugs, which impaired his memory of the events.
The taking of the wristwatches and other items was not part of a premeditated robbery but rather an afterthought.

There was no direct evidence linking him to the killings since no eyewitness directly saw him commit the actual stabbings.
The testimony regarding the possession of stolen items was, in part, hearsay, particularly the account of how the items were discovered during a frisking.

The Regional Trial Court originally found the appellant guilty beyond reasonable doubt and sentenced him to reclusion perpetua on three counts with additional penalties and indemnifications.
On appeal, the appellant raised issues regarding the sufficiency of evidence, the classification of the crime as "robbery with multiple homicide," and the imposition of the penalty.

Whether the evidence presented is sufficient to convict the appellant beyond reasonable doubt for the complex crime charged.
Whether the testimonies and physical evidence (including the recovery of stolen items and forensic findings) establish his guilt.

Whether the crime should be categorised as "robbery with multiple homicide" or as separate offenses of homicide and theft.
Determining if the requisite criminal design (i.e., the intent to commit robbery preceding the homicide) was sufficiently established.

Whether the testimony of Pat. Orig regarding the discovery of wristwatches and remote control is admissible and not merely hearsay.
Whether the witnesses’ accounts collectively establish an intimate connection between the act of robbery and the homicides.

Whether the defense of intoxication and drug use can mitigate or exculpate the appellant from the charges due to impaired mental faculties.