Case Digest (G.R. No. 87085)
Facts:
People of the Philippines v. Manolito Tolentino @ "Bong", Carlito Tala @ "Boy", Rodolfo Matawaran and @ John Doe, G.R. No. 87085, February 02, 1993, Supreme Court Second Division, Nocon, J., writing for the Court.
Accused-appellant Carlito Tala appealed his conviction for robbery with multiple homicide and serious physical injuries. He had been tried jointly with Manolito Tolentino and Rodolfo Matawaran (and an unnamed John Doe) in Criminal Case No. G-1627 before the Regional Trial Court (RTC) of Guagua, Pampanga, Branch 51. The RTC rendered a decision dated September 7, 1988 finding Tala, Tolentino and Matawaran guilty beyond reasonable doubt as co-principals; it imposed reclusion perpetua on each, ordered accessory penalties, confiscated the weapon, and directed solidary indemnity and damages to the victims’ heirs and to the offended couple.
The amended information charged that on or about November 8, 1983 the accused entered the house of Adelaida Lingad, forcibly broke a comfort-room window grill, stole P4,000.00 and, armed with a scythe, stabbed three children (Glenly, Enrique and Geraldine/Irene) causing their deaths and inflicted serious physical injuries on their niece Grace Paule. Upon arraignment Tala and Matawaran pleaded not guilty; Tolentino later changed his plea to guilty in open court. The prosecution presented testimony that the intruders entered at night, that the children were left alone, that Grace Paule positively identified Tolentino, Tala and Matawaran at trial, and that Geraldine, while dying, named “Bong-Bong” (Tolentino) and made a three-finger sign allegedly identifying the other assailants.
Tala offered an alibi: he claimed he and Matawaran were in Dinalupihan, Bataan late on November 7 and returned to Lourdes, Lubao, arriving about 3 a.m., and slept there; they were later apprehended at that residence. The RTC rejected the alibi as not clear, convincing or plausible and held that a credible positive identification by Grace Paule and corroboration by Adelaida Lingad outweighed the alibi. The RTC also admitted an extrajudicial confession by Tolentino implicating others.
On appeal to the Supreme Court, Tala argued among other things that (a) the extrajudicial confession of Tolentino was inadmissible against him under the res inter alios acta doctrine, (b) the extrajudicial statements by Geraldine were not res gestae, and (c) his alibi was sufficient to raise reasonable doubt. The Supreme Court reviewed the evidence, applied res ges...(Pro-only)
Issues:
- Is the extrajudicial confession of co-accused Manolito Tolentino admissible against accused-appellant Carlito Tala?
- Did the evidence, including eyewitness identification and alleged res gestae statements, establish defendant Tala’s guilt beyond reasonable doubt despite his alibi?
- Should the indemnity awarded ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)