Title
People vs. Tawat
Case
G.R. No. L-62547
Decision Date
Dec 21, 1983
Four individuals were convicted of robbery with homicide and frustrated homicide, leading to a life sentence after a store robbery resulted in one death and one injury.
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Case Digest (G.R. No. L-62547)

Facts:

  • The case involves the People of the Philippines as the plaintiff-appellee against Felicito Tawat, Jimmy Tarraya, Nestor Rojo, and Roque Base as the accused.
  • The events occurred on November 30, 1980, in Bugao, Bagamanoc, Catanduanes.
  • The accused were charged with robbery with homicide and frustrated homicide in Criminal Case No. 906 in the Court of First Instance of Catanduanes.
  • Between November 24 to 29, 1980, the accused conspired to rob the store of spouses Pedro Lim and Jovita Lim y Sesalem.
  • On the night of the incident, Tawat stabbed Mrs. Jovita Lim, leading to her immediate death.
  • Tarraya struck Mr. Pedro Lim with a piece of wood, rendering him unconscious.
  • Rojo acted as a lookout during the crime.
  • The accused stole approximately P110.00 from the store's cash drawer.
  • The trial court found the accused guilty, citing aggravating circumstances such as evident premeditation, treachery, and the use of superior strength.
  • Roque Base was dismissed from the case due to insufficient evidence against him.
  • Tawat and Tarraya were sentenced to death, while Rojo received a lesser sentence due to his minority.
  • The case was automatically reviewed by the Supreme Court due to the death penalty imposed.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the trial court's finding that the special complex crime of robbery with homicide was committed and that the accused were guilty.
  • The Court upheld the trial court's ruling that the accused were guilty of frustrated homicide.
  • The Court confirmed that there was sufficient evidence to establish ...(Unlock)

Ratio:

  • The Supreme Court reasoned that the evidence, including witness testimonies and confessions, established the accused's guilt beyond a reasonable doubt for robbery with homicide and frustrated homicide.
  • The actions of Tawat, Tarraya, and Rojo demonstrated a clear conspiracy, as they arrived together, executed the crime in coordination, and fled as a group.
  • Aggravating circumstances such as treachery and the crime being committed ...continue reading

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