G.R. No. 142641 - Arceo, Jr. vs. People

On January 24, 1984, the accused—Carlito Tala alias “Boy”, Manolito Tolentino alias “Bong”, Rodolfo Matawaran, and an unidentified John Doe—were charged with robbery with multiple homicide and serious physical injuries.
The charges arose from events occurring on or about November 8, 1983, in the municipality of Lubao, Pampanga, where the crime was committed.

The incident occurred at the residence of Adelaida Lingad, who had temporarily left her three minor children and her niece to attend a wake.
The accused forcibly broke the wooden window grill of the comfort room to enter the house.
Once inside, they demanded the location of hidden cash (P4,000.00) from the children.
Under threat and terror, the children indicated the location of the cash, leading to the occurrence of the crime.

Manolito Tolentino seized the money and, armed with a scythe, initiated a stabbing attack.
The stabbing resulted in fatal injuries to three of the children (Glenly, Enrique, and Geraldine) and caused serious physical injuries to the surviving victim, Grace Paule.
The scythe used in the commission of the crime was later confiscated by the state as evidence.

At arraignment, Tala, Tolentino, and Matawaran pleaded “Not Guilty” while Tolentino later altered his plea to “Guilty” in open court.
The Regional Trial Court of Guagua, Pampanga, after a careful review of the evidence, found the accused guilty as co-principals beyond reasonable doubt.
The court determined that the evidence had reached a degree of moral certainty, substantiating all essential elements of robbery with homicide.

Grace Paule, the sole surviving victim, testified in court, positively identifying the accused based on her firsthand experience during the attack.
Her extrajudicial statement, taken while she was groggy and delirious from her injuries, was given full probative value despite her condition.
Additional testimony was provided by Adelaida Lingad, who reported the immediate aftermath of the crime, including the identification given by her dying daughter Geraldine.
The testimonial evidence clearly indicated that the accused, including Tala, were present at the scene of the crime.

Accused-appellant Tala asserted an alibi, claiming he was in Bataan at the time of the occurrence; however, the court found his testimony inconsistent and not credible.
The defense contended that the extrajudicial statement of Grace Paule, taken by Fiscal Abiog—omitting specific names until later prompted—should not be allowed to implicate him.
The trial court and subsequently the appellate court rejected the alibi and upheld the credibility of the identification testimonies and associated extrajudicial statements.
Accused Tala also argued that the extra-judicial confession of Tolentino (implicating him) should not be used against him since Tolentino later admitted in open court that he acted alone; this contention was later addressed by noting that under the principle of res inter alios acta, such confession could not automatically bind the co-accused absent specific conditions.

Whether the evidence, particularly the identification by Grace Paule and the corroborative testimony of Adelaida Lingad, was sufficient to establish the accused-appellants’ guilt beyond reasonable doubt.

Whether Grace Paule’s extrajudicial statement, taken while she was delirious and before her later identification of the accused, should be accorded full probative value.
The implications of such statements in light of the accused’s defense.

Whether the alibi presented by accused-appellant Tala, alleging his presence in Bataan at the time of the crime, was credible and sufficient to exonerate him.
The impact of logistical feasibility and proximity of the alleged location of events on the validity of the alibi.

Whether the extra-judicial confession of Tolentino, which implicated Tala, could be used against the latter under the principle of res inter alios acta, considering subsequent admissions made in open court.