Case Summary (G.R. No. 208527)
Applicable Law
The applicable law includes Article 294, paragraph (1) of the Revised Penal Code, as amended by Section 9 of Republic Act No. 7659, which outlines the penalties for the crime of robbery with homicide.
Factual Background of the Incident
On March 24, 2003, at approximately 4:45 PM, Bacero, along with five accomplices, attacked Juliet and Jun while they were picnicking. The assault involved the use of deadly weapons, where Bacero stabbed Jun and robbed him of his cellphone. Juliet was restrained, but managed to identify Bacero as one of the attackers after the incident.
Identification of the Accused
Juliet's identification of Bacero occurred shortly after the crime, which was corroborated by subsequent police investigations. Although Bacero initially denied the allegations, he later confessed to the robbery and homicide under police custody. This confession, however, faced scrutiny regarding whether it was coerced.
Trial Court Findings
The Regional Trial Court (RTC) found Bacero guilty of Robbery with Homicide, primarily based on Juliet's positive identification and the evidence presented. The RTC's decision emphasized the promptness of the identification and the absence of evidence supporting defense assertions regarding mistaken identity.
Court of Appeals Ruling
Bacero appealed the RTC's ruling, challenging the credibility of Juliet's testimony. However, the Court of Appeals upheld the RTC’s findings, determining that there was no sufficient reason to question the credibility of Juliet's identification. They affirmed the conviction and modified the damages awarded to the victim’s heirs.
Supreme Court Review
The Supreme Court considered the appeal on points of law regarding the sufficiency of evidence, the credibility of witness testimony, and the legal standards governing confessions obtained during custodial investigation. The Court ruled that the prosecution met the requisite burden of proof and that the defenses of mistaken identity and torture presented by Bacero were without merit.
Extra-Judicial Confession and Admissibility
Bacero claimed that his confession was coerced, yet there was no proof of torture or physical harm presented. The confession itself was deemed inadmissible, as it did not comply with legal procedural requirements set forth in R.A. No. 7438 regarding custodial investigation.
Positive Witness Identification
The Supreme Court underscored that credibility assessments made by both the trial and appellate courts are given great weight, especially when consistent testimony is provided. Juliet's identification satisfied the totality of circumstances test established in previous jurisprudence, demonstrating her opportunity to view the perpetrator amidst the chaos of the attack.
Defense of Alibi and Mistaken Identity
Bacero's defense rested on claims of alibi and mistaken identity, which the Court found to be weak and unconvincing. The absence of substantial corroborating evidence for Bacero's claims reinforced the validity of the victim's identification. The Court has maintained that mere denial cannot outweigh positive identification by a credible witness, particularly when the defense fails to establish the impossibility of being at the crime scene.
Robbery with Homicide Analysis
The Supreme Court elucidated the elements required to convict for Robbery with Homicide, emphasizing the necessity of proving the robbery and the circumstances surrounding the homicide. In this case, the combined forc
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Case Citation
- 790 Phil. 745; 113 OG No. 18, 3266 (May 1, 2017)
- G.R. No. 208527, July 20, 2016
Parties Involved
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Ardo Bacero y Casabon
Procedural History
- The case is an appeal against the July 26, 2012 Decision of the Court of Appeals (CA) affirming the January 11, 2011 Decision of the Regional Trial Court (RTC) of Antipolo City, Branch 73.
- The RTC found the accused-appellant guilty beyond reasonable doubt of the special complex crime of Robbery with Homicide, as defined under Article 294, paragraph (1) of the Revised Penal Code.
Facts of the Case
- On March 24, 2003, Juliet Dumdum-Bimot and her boyfriend, Virgilio "Jun" San Juan, Jr. were attacked by six men while picnicking in Taytay, Rizal.
- The accused-appellant was identified as the assailant who stabbed Jun and stole his cellphone, while another assailant restrained Juliet.
- Juliet managed to escape and sought help from security guards, subsequently identifying the lifeless body of Jun.
- Juliet later identified the accused-appellant as one of the attackers, having seen him frequently in her neighborhood.
Charges and Information
- The Information filed on March 27, 2003, charged Ardo Bacero y Casabon and several unidentified co-accused with Robbery with Homicide.
- The victims were stated to have suffered losses amounting to Php6,970.00, alongside the fatal stabbing of Jun.
Trial Proceedings
- During trial, the accused-appellant pleaded not guilty.
- Juliet’s identification was pivotal as she recognized the accused-appellant from her previous sightings.
- The accused-appellant claimed alibi, asserting he was home at the time of the cri