G.R. No. 200712 - Abuda vs. L. Natividad Poultry Farms

On April 17, 1947, Patricia Sonsona, a 45-year-old single woman residing in Barrio Ocana, Carcar, Cebu, was at home alone when a robbery occurred.
Along with her, an 11-year-old girl, Lucia Sobrevilla, was also present in the house and became an eyewitness to the events.

Two men, whose faces were concealed by handkerchiefs, entered the house. One of them, later identified by Lucia as “Orok” (Jorge Sonsona), and the other, Eusebio Mejares, were directly involved in the crime.
The intruders searched the house, with one obtaining a key from Patricia after a brief exchange and subsequently assaulting her.
Patricia was choked to death during a struggle where one assailant sat on her abdomen and forcibly held her down, ultimately causing fatal asphyxia and pulmonary hemorrhage.

Lucia Sobrevilla, awakened by the intruders, witnessed the sequence of events, including being dragged aside and forced to silence, as well as identifying Jorge Sonsona and Eusebio Mejares during the incident.
Carmen Cajo, residing 20 brazas away, encountered Jorge Sonsona on her way to investigate the disturbance and later saw him again near Patricia’s house, during which he made incriminating remarks regarding his desire to kill Patricia.
Additional witnesses, such as Marcelo Sonsona, Anastacio Alcordo (Chief of Police of Carcar), Mrs. Lourdes Ladonga, and Mariano Alcantara, provided testimonies corroborating the events surrounding the robbery and homicide, including evidence of the robbery, scattered belongings, and interactions with the accused on subsequent days.

The President of the 15th Sanitary Division examined Patricia’s body and documented various physical injuries including scratches, contusions, and evidence of strangulation, ultimately certifying asphyxia due to strangulation and pulmonary hemorrhage as the cause of death.
The thorough medical report served as physical corroboration of the violent act that led to Patricia Sonsona’s demise.

Jorge Sonsona’s defense centered on an alibi, claiming he had left Carcar by April 15, 1947, aboard the M/S Virginia for Misamis, and subsequently traveled to Davao.
Two witnesses, Jose Aug and Edilberto Ortiz, testified in support of this alibi, recounting his presence on board the vessel.
The prosecution challenged the alibi by introducing the manifest of the M/S Virginia, which failed to list Jorge Sonsona or corroborate the timeline and related testimony.
Additional rebuttal witness testimonies from Mrs. Lourdes Ladonga and Mariano Alcantara further discredited the alibi by situating the accused in Cebu on April 16, 1947.

The accused was reported to have urgently needed money, as evidenced by his request for backpay and his claim of possessing only P19 at the time, which provided a strong motive for committing the crime.
The particular occurrence took place in the victim’s dwelling—a recognized aggravating circumstance in crimes of robbery with homicide.

Whether the alleged discrepancies in the testimony of the principal witness, Lucia Sobrevilla, arising from the loss or reconstitution of the original trial notes, undermine her credibility.
The impact of time on the recollection of details by both Lucia Sobrevilla and Carmen Cajo, and if such discrepancies affect the identification of the accused.

Whether the alibi presented by Jorge Sonsona, supported by the testimonies of Jose Aug and Edilberto Ortiz, is credible in light of contradictory documentary evidence (i.e., the manifest of M/S Virginia).
How the oral nature of the alibi evidence compares to the more reliable written records in establishing the whereabouts of the accused.

The determination of whether the aggravating circumstance of dwelling was sufficient to justify the imposition of a heavier penalty, possibly even the death penalty.
The evaluation of the alleged aggravating circumstances of abuse of superior strength and use of disguise, and whether they are applicable in this case.

Whether the combined testimonies, physical evidence, and discrediting of the alibi conclusively prove the participation of the accused in the crime of robbery with homicide.