Case Digest (G.R. No. 172243)
Facts:
In the case titled The People of the Philippines vs. Norberto Villagracia, et al., the appeal revolves around a conviction related to robbery with frustrated homicide. The incident occurred on the evening of September 30, 1987, in Barangay Tan-ag, Lopez, Quezon, where the victims, Alejo and Lourdes Flavier, along with their family, were gathered at their home. At about eight o'clock, Lourds Flavier responded to a knock at their store door, where several individuals, who falsely claimed to be members of the New People's Army, requested to speak with Alejo Flavier. When Alejo met these men, they demanded food, and as Alejo went to fetch some, four of the intruders followed him into the house, revealing weapons and demanding money.
Despite Alejo's assurances that they would provide what was asked, Alejo was subsequently stabbed in the back by one of the assailants, Nelson Ledesma. Lourdes managed to escape, with Alejo following her, but not before the robbers extorted
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)