Case Digest (G.R. No. 99355)
Facts:
People of the Philippines v. Domingo Salazar y Seroma alias Inggo, Monchito Gotangugan y Sevilla alias Monching and John Doe, G.R. No. 99355, August 11, 1997, Supreme Court Third Division, Panganiban, J., writing for the Court.
In an Information dated July 31, 1989, the Assistant Quezon City Prosecutor charged respondents Domingo Salazar and Monchito Gotangugan (with one John Doe) with robbery with homicide for the March 10, 1989 killing of security guard Crispin Gatmen at Lindas Supermarket in Quezon City and for the alleged taking of Gatmen’s service revolver. The Regional Trial Court (Quezon City, Branch 104), sitting as a special criminal court and presided by Judge Maximiano C. Asuncion, convicted both accused of robbery with homicide and, by a Judgment dated April 1, 1991, sentenced each to reclusion perpetua and ordered indemnities and costs.
At trial the prosecution presented police testimony and two eyewitnesses, Vicente Miranda, Jr. and Pedro Soriano, who described seeing three men approach Gatmen about 3:30 a.m., one man pull out a dagger and hand it to another, and the latter stab Gatmen repeatedly while the third kept lookout; the assailants then took the revolver and fled. The medico-legal report listed multiple stab wounds and lacerations consistent with a violent attack; the firearm’s value was established between P6,000–P6,500. The defense offered alibi testimony from both appellants, who claimed they were at home when police later arrested them (July 27, 1989) and alleged mistreatment; they also denied prior acquaintance with the eyewitnesses.
On appeal to the Supreme Court (the appeal being direct to this Court because of the reclusion perpetua penalty), appellants argued (1) the trial court erred in believing the eyewitnesses whose testimonies were allegedly inconsistent and improbable, (2) the evidence was insufficient to support conviction, and (3) appellants were arrested without warrant so that evidence obta...(Subscriber-Only)
Issues:
- Did the trial court err in crediting the prosecution eyewitnesses and was the evidence sufficient to sustain the conviction as charged?
- Were the eyewitness testimonies rendered inadmissible by appellants' alleged warrantless and illegal arrest?
- Given the proved facts, can appellants be convicted of the special complex crime of robbery with homicide under Article 294 of the Revised Penal C...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)