Case Digest (G.R. No. L-51387)
Facts:
The People of the Philippines v. Jimmy Trawon, Serapio Crodua and Dionisio Sedon, G.R. No. L-51387, February 24, 1981, Supreme Court Second Division, Abad Santos, J., writing for the Court.The People of the Philippines (plaintiff-appellee) prosecuted Jimmy Trawon, Serapio Crodua and Dionisio Sedon (accused-appellants) for Robbery with Homicide under Art. 294, Revised Penal Code, in an information dated April 25, 1975, arising from an incident of February 24, 1975 in Samal, Davao. The information alleged that the accused, armed and acting in concert, entered the house of Filomeno Montilla, took valuables and cash, and that one or more of them attacked Montilla with a blunt instrument causing his death.
After trial in the Court of First Instance of Davao, Branch VIII at Tagum, the trial court, by decision dated July 28, 1978, found the three accused guilty beyond reasonable doubt of robbery with homicide and sentenced each to reclusion perpetua, ordered them to indemnify the heirs P12,000.00 and to restitute or pay P315.00, with costs. The accused appealed their conviction to the Supreme Court and were meanwhile admitted to provisional liberty upon posting bail bonds of P30,000.00 each; the trial court had placed an unusual condition relating to original title copies in the bond record, but xerox copies only were actually in the record.
Prosecution eyewitnesses — notably Emmanuel and Josue Monter (grandchildren of the deceased) and a neighbor, Marcial Minosa — testified that four men forced entry about 6:30 p.m.; Filomeno ripped off a mask from one intruder who then struck him on the neck with an iron bar scale; Emmanuel positively identified Jimmy Trawon as the masked man whose mask was removed, pointed out Serapio Crodua as the man with a pistol and Dionisio Sedon as the one with a knife; Marcial, a 15‑year‑old, identified Dionisio as the person who fired at Isidro Bejor during the incident. The municipal health officer performed a post mortem, attributing death to cerebral concussion from a blunt instrument.
Each accused asserted an alibi: Jimmy said he was at home building his house and later at a neighbor’s until 9:00 p.m. (corroborated by Rocario Barbarona); Serapio and Dionisio said they were playing chess at Pedro Aguhog’s home from 4:00 to 9:00 p.m. (corroborated by Pedro Aguhog). The appellants argued the identity of the perpetrators was not proven beyond reasonable doubt, asserting defective confro...(Subscriber-Only)
Issues:
- Whether the prosecution established the identity of the accused beyond reasonable doubt. ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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