Case Digest (G.R. No. 233659)
Facts:
People of the Philippines v. John Sanota y Sarmiento, Deo Dayto y Genorga @ "Rubrob" and Rolando Espineli y Acebo @ "Landoy", G.R. No. 233659, December 10, 2019, First Division, Peralta, C.J., writing for the Court.On March 31, 2011, Santiago Abion, Jr. observed appellants drinking at a hut near his house and overheard them planning to raid a house in Hacienda 8 and saying that anyone who blocked their path would be killed. Later that evening, appellant Rolando Espineli invited Abion to a supposed birthday party but instead rode with him toward Hacienda 8; Espineli left Abion near the Quiros residence, went inside, and shortly thereafter Abion saw Deo Dayto climb through an open window carrying a gun after Espineli handed him the weapon. Abion heard a gunshot; Dayto exited the window holding a gun and a "black thing" and fled with Sanota and Espineli, while Jose Miguel Quiros (the victim) was later found shot and died.
A Sinumpaang Salaysay executed by Abion dated April 5, 2011 led to an Information charging the three appellants with Robbery with Homicide under Article 294 of the Revised Penal Code; they pleaded not guilty at arraignment. The prosecution presented eyewitness testimony (Abion, Lee Won Young) and police and security-agency witnesses; the defense offered denial and alibi testimony from each appellant (Espineli claimed security-guard duty, Dayto claimed attendance at a birthday in Cavite, Sanota claimed to have been gathering wood and visiting friends).
The Regional Trial Court (RTC), Branch 25, Biñan, Laguna, convicted the three appellants on August 20, 2014 of Robbery with Homicide and sentenced them to reclusion perpetua and ordered payment of various damages. The Court of Appeals (CA) affirmed in a Decision dated February 15, 2017, holding that circumstantial evidence and eyewitness Abion’s testimony sufficiently established guilt beyond reasonable doubt. The case was subsequently brough...(Pro-only)
Issues:
- Did the trial court (as affirmed by the Court of Appeals) err in convicting the appellants based on the testimony of prosecution eyewitness Santiago Abion, Jr. and circumstantial evidence?
- Did the prosecution prove the appellants’ guilt beyond reasonable doubt for Robbery with Homicide under Article 294 of the Revised Penal Code?
- Was the award of P100,000 as attorney’s fees supportable wi...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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