Case Digest (G.R. No. 100391-92)
Facts:
People of the Philippines v. Mariano Timple, G.R. Nos. 100391-92. September 26, 1994, Supreme Court Third Division, Feliciano, J., writing for the Court. The prosecution charged Mariano Timple and nine others in two informations (Crim. Case Nos. 505-G and 506-G) with robbery with multiple homicide (Article 294, Revised Penal Code) and related rapes arising from two successive attacks on the night of February 8, 1989, in Barangay Culong, Guimba, Nueva Ecija. The informations alleged that an armed group entered the households of the Semacios and the Samoys, hogtied occupants, ransacked the houses, raped women (Zenaida Semacio and Elvira Samoy), and killed a total of twelve persons; the accused were said to have acted with firearms and bladed weapons, in conspiracy, and with intent to gain.At trial the cases were tried jointly. Survivors Zenaida Semacio, Arnold Semacio, and Elvira Samoy testified that they recognized Timple among the armed men; they later identified him in a police line‑up held on February 10, 1989. Timple denied meaningful identification and claimed the line‑up was manipulated — that he was coached into view with a bonnet placed and removed by a captain — and argued lack of counsel during the line‑up. The prosecution presented evidence of prior suspicion, a photograph shown to victims, the physical presence of Timple near scene earlier that day, and the victims’ in‑court and line‑up identifications.
The Regional Trial Court, Branch 32, Guimba, Nueva Ecija found Mariano Timple (together with Bernardo Gudoy, Randy Sagun, and Rudy Maiquez) guilty beyond reasonable doubt of robbery with homicide in both cases (treating rape as an aggravating circumstance), sentenced them to reclusion perpetua on each case, ordered indemnities to victims’ h...(Subscriber-Only)
Issues:
- Was the identification of Mariano Timple by the prosecution witnesses proven beyond reasonable doubt and admissible despite the challenged police line‑up?
- Was conspiracy proved so that each accused could be held liable for the killings and robberies committed by the group?
- Were the aggravating circumstances correctly applied — specifically, was treachery properly appreciated and how should multiplicity of victims and rape be treated for purposes of penalty?
- Could the death penalty under Republic Act No. 7659 (amending Article 294)...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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