Title
People vs. Villa
Case
G.R. No. L-31401
Decision Date
Oct 30, 1979
Four men posed as PC rangers, robbed, killed Juan Acosta, and raped his wife; convicted of robbery with homicide and rape, death penalty upheld.
A

Case Digest (G.R. No. L-31401)

Facts:

Juan Acosta was killed in Barrio Buyon, Municipality of Bacarra, Ilocos Norte, on June 28, 1968, and the spouses’ house was ransacked by four men allegedly posing as P.C. Rangers. The 121st P.C. Company apprehended accused Anastacio Salcedo, Pepito Villa, Norberto Salcedo, and Ernesto Salcedo around two hours after midnight in a Manila-bound bus at Badoc, Ilocos Norte, where items looted from the Acostas were recovered.

The Municipal Court disposed of Criminal Case No. 942 (illegal possession of firearms and ammunition) by sentencing Norberto Salcedo after a guilty plea, while Criminal Cases 939, 941, and 940 were forwarded to the trial court; the rape case was dismissed and consolidated with the robbery case. The trial court convicted the accused in Criminal Case No. 5199-III for Robbery with Homicide, attended by the aggravating circumstance of rape, and acquitted them in Criminal Case No. 5201 (usurpation of official function) for insufficiency of evidence; the accused appealed.

Issues:

  • Which of the conflicting versions of the prosecution and the defense as to how the crimes were committed is credible?
  • Whether the accused’s extrajudicial confessions (Exhibits “A”, “B”, “C”, and “D”) were given voluntarily or were extracted by force and intimidation?
  • Whether the accused were properly convicted of Robbery with Homicide, with the rape as an aggravating circumstance, and with the other aggravating circumstances alleged and proved.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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