Case Digest (G.R. No. 110037)
Facts:
The People of the Philippines v. Eduardo Pulusan y Aniceta, Rolando Rodriguez y Macalino, Rolando Tayag and John Doe alias Ramon/Efren, G.R. No. 110037, May 21, 1998, Supreme Court Third Division, Kapunan, J., writing for the Court.On the evening of January 20, 1986, a passenger jeepney traveling along the MacArthur (Bulacan–Pampanga) Highway was boarded at Barangay Tikay, Malolos by a group of four men who then announced a hold-up, armed with knives and an improvised shotgun ("sumpak"). The driver, Constancio Gomez, and passengers — including seventeen‑year‑old Marilyn Martinez and Cresenciano Pagtalunan — were divested of money and valuables. The robbers then drove to a secluded area in San Simon, Pampanga; four male passengers were subsequently clubbed and stabbed to death and Marilyn Martinez was repeatedly raped by the assailants, while Gomez and two others survived and later reported the incident.
Police investigation followed. An initial investigator prepared a report and, after a tip, police located and arrested Eduardo Pulusan and Rolando Rodriguez on January 23–24, 1986; several items allegedly taken from the victims (camera, watches, improvised shotgun, shells, shoes, etc.) were recovered at Rodriguez’s residence and inventoried. The surviving victims positively identified Pulusan and Rodriguez at the police headquarters; photographs of the identification were taken. The wives of the deceased identified cadavers at the funeral parlor, and autopsy certificates established causes of death as hemorrhage and multiple stab wounds. Medical examination of Marilyn Martinez documented fresh lacerations to the hymen and other injuries.
An information charging Pulusan and Rodriguez (later amended to include Rolando Tayag and John Doe alias Ramon/Efren) with highway robbery attended with multiple homicide and multiple rape was filed in the Regional Trial Court (RTC), Branch 12, Malolos, Bulacan. Pulusan and Rodriguez pleaded not guilty and presented alibi witnesses. After trial, the RTC convicted Pulusan and Rodriguez of robbery with homicide (Article 294(1), Revised Penal Code) and sentenced each to reclusion perpetua, ordering indemnities, moral damages, funeral expenses and return/reimbursement for stolen items; warrants against Tayag and John Doe remained outstanding. Pulusan and Rodriguez appealed to the Supreme Court, challenging witness identifications, the weight of the prosecution evidence, and the sufficie...(Pro-only)
Issues:
- Did the trial court err in crediting the identification and testimony of the prosecution eyewitnesses and therefore in finding the accused guilty beyond reasonable doubt?
- Were the accused shown to have participated in a conspiracy to commit the robbery, such that each is criminally liable for the killings and the rape committed in its course?
- Was the RTC correct in construing and convicting the accused under Article 294(1) of the Revised Penal Code (robbery with homicide) instead of under the Anti‑Highway Robbery law (PD 532), and what penalty is properly imposed considering the attendant rape and the constitutional prohibition of death penalty at the relevant time?
- Were the awards of civil indemnity, moral dama...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)