Case Digest (G.R. No. 80042)
Facts:
- On June 30, 1986, three decomposed bodies were found in Barangay Tuaco, Basud, Camarines Norte.
- The victims were identified as Alexander Sy, Augusto Gabo, and Frisco Marcellana, showing signs of foul play.
- An information for robbery with multiple homicide was filed against Adolfo Quinones, Alfredo Aban, Zaldy Civico, Ronilo Canaba, Amado Conda, Jr., Santiago Solarte, Armando Buitre, and one John Doe.
- During arraignment on November 13, 1986, some accused pleaded not guilty, but later, Conda, Canaba, and Quinones changed their pleas to guilty.
- Conda later withdrew his guilty plea and re-entered a plea of not guilty.
- The prosecution presented evidence that the victims were intercepted and killed by the accused, who stole valuables from them.
- The victims were reported to have significant cash and items, including a handgun.
- Conda implicated others, leading to the apprehension of Solarte.
- Quinones and Canaba provided extra-judicial statements identifying weapons used in the crime.
- Despite claims of torture by Quinones, the trial judge found no evidence of coercion.
- The trial court convicted all accused (except Solarte and Buitre) based on the evidence.
Issue:
- (Unlock)
Ruling:
- The trial court's conviction for robbery with multiple homicide was incorrect; it should have been robbery with homicide.
- The penalty was modified to a single term of reclusion perpetua for robbery with homicide.
- The extra-judicial confessio...(Unlock)
Ratio:
- The Supreme Court ruled that the trial court erred in convicting the accused of robbery with multiple homicide, as the Revised Penal Code does not recognize this charge.
- The correct charge is robbery with homicide, regardless of the number of victims.
- The penalty for robbery with homicide is reclusion perpetua, imposed only once, irrespective of the number of victims.
- The Court noted that discu...continue reading
Case Digest (G.R. No. 80042)
Facts:
On June 30, 1986, the bodies of three men were discovered in a wooded area in Barangay Tuaco, Basud, Camarines Norte. The corpses were in an advanced state of decomposition and exhibited various contusions, stab wounds, bullet wounds, and other injuries indicative of foul play. The victims were later identified as Alexander Sy, Augusto Gabo, and Frisco Marcellana. Subsequently, an information for robbery with multiple homicide was filed against Adolfo Quinones, Alfredo Aban, Zaldy Civico, Ronilo Canaba, Amado Conda, Jr., Santiago Solarte, Armando Buitre, and one John Doe. During their arraignment on November 13, 1986, Quinones, Canaba, Aban, Civico, and Conda initially pleaded not guilty. However, on November 20, 1986, Conda, Canaba, and Quinones changed their pleas to guilty. On April 1, 1987, Conda was permitted to withdraw his guilty plea and re-enter a plea of not guilty. Solarte remained at large, while Buitre was killed in a police encounter. Judge Luis D. Dictado of the Regional Trial Court of Daet, Camarines Norte, ordered the prosecution to present evidence against Quinones and Canaba despite their guilty pleas, which they maintained even after being informed of the potential consequences, including the death penalty. The prosecution's evidence established that the three victims were intercepted while driving a dark blue Mitsubishi car along the Maharlika Highway on the evening of June 27 or 28, 1986, by the accused, who had placed sacks on the road to block their path. The victims were subsequently taken to the nearby woods where they were killed. Alexander Sy was reported to be carrying P300,000.00, a necklace worth P20,000.00, a P10,000.00 diamond ring, and a licensed .22 caliber handgun at the time of the incident. The accused stole these items and used the victims' car to flee to...