Title
People vs. Villagracia
Case
G.R. No. 94471
Decision Date
Mar 1, 1993
Armed intruders, posing as NPA, robbed and stabbed a family, abducting one member; accused convicted of robbery with frustrated homicide.

Case Digest (G.R. No. 172243)

Facts:

  • Incident and Setting
    • On the evening of September 30, 1987, at around eight o’clock in Barangay Tan-ag, Lopez, Quezon, the spouses Alejo and Lourdes Flavier, their daughter-in-law Regulita Flavier, and other close relatives were inside their two-story house.
    • The family was watching television upstairs when a knock was heard at the door of the ground floor store attached to the house.
  • Entry and Demand for Money
    • The visitors introduced themselves as members of the New People’s Army and expressed their desire to speak with Alejo Flavier.
    • Alejo descended to meet them and, along with his wife, assured the intruders that money would be provided if they refrained from causing harm.
  • Escalation into Robbery with Frustrated Homicide
    • Upon ascending to fetch the money, Alejo was followed by four armed robbers, who then advanced to the second floor; despite Alejo’s protests, the intruders threatened the occupants with weapons.
    • Specific actions during the crime included:
      • Nelson Ledesma poking a gun at Alejo and later stabbing him in the back with a knife, an act that nearly resulted in Alejo’s death.
      • Norberto Villagracia pointing his firearm at Regulita Flavier and Wilfredo Gampa brandishing a balisong, while Nixon Ledesma, initially outside, later joined the group.
      • Alfonso Pastoral and Elmer Paglinawan displaying their balisongs, thereby heightening the threat.
  • Robbery and the Aftermath
    • The robbers demanded money and valuables, extracting a sum of P2,500.00 in cash along with rings, necklaces, and a radio cassette, in addition to assorted goods such as sardines and cigarettes amounting to P10,195.00.
    • Regulita Flavier was forcibly taken to the barangay hall from where she later escaped, while Alejo Flavier, after being stabbed, was rushed to a hospital where he underwent surgery and spent nine days recovering, with the attending physician confirming that the stab wounds could have been fatal without prompt medical intervention.
    • During the subsequent investigation, all six accused-appellants were positively identified by the victims as the perpetrators; however, in the course of the proceedings, accused Elmer Paglinawan escaped confinement and was later killed, leading to the dismissal of the case against him.
  • Accused-Appellants’ Defense and Alleged Inconsistencies
    • The accused-appellants relied on testimonial inconsistencies, denial, and alibi in their defense, asserting that:
      • The prosecution’s evidence was insufficient to prove their guilt beyond reasonable doubt for robbery with frustrated homicide.
      • The witnesses’ contradicting accounts—including discrepancies between Regulita Flavier’s and Alejo Flavier’s testimonies regarding the stabbing—should raise doubt about their involvement.
    • They also contended that their confessions were extracted under duress, claiming maltreatment and lack of proper legal counsel during the process.
  • Prosecution’s Evidence and Trial Court Findings
    • The prosecution substantiated their case with consistent testimonies from three eyewitnesses, which placed the accused at the scene of the crime in a well-lit environment.
    • Affirmative evidence, including the medical testimony of Dr. Teodoro Serrano regarding the near-fatal stab wounds, reinforced the credibility of the prosecution’s witnesses.
    • The trial court found that all accused-appellants, except the one who escaped and was subsequently killed, acted in concert, and their individual accounts of alibi failed to corroborate their claims of innocence.

Issues:

  • Sufficiency of the Prosecution’s Evidence
    • Whether the evidence presented by the prosecution was adequate to establish, beyond reasonable doubt, the guilt of the accused for the crime of robbery with frustrated homicide.
    • Whether the eyewitness testimonies, supported by medical evidence, effectively neutralized the defense based on denial and alibi.
  • Credibility and Consistency of Witnesses
    • The issue of conflicting accounts between Regulita Flavier and Alejo Flavier regarding who inflicted the fatal or near-fatal stab wounds.
    • Whether the alleged inconsistencies in the testimony of the People’s witnesses, including the identification process, could raise reasonable doubt regarding the accused-appellants’ involvement.
  • Validity and Impact of Confessions
    • Whether the alleged forced nature of the confessions of the accused-appellants, executed under claims of duress, undermined the prosecution’s case.
    • Whether the trial court was justified in not considering the confessions when determining criminal culpability due to the weight of the eyewitness evidence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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