Case Summary (G.R. No. L-37400)
Applicable Law
The case falls under the 1987 Philippine Constitution and involves a charge of robbery with homicide, as defined under Article 294 (1) of the Revised Penal Code.
Incident Overview
On January 25, 1971, Cabato, along with two masked accomplices, allegedly entered the Guinit residence with the intent to rob. The accusation stated that during the commission of the robbery, the accused attacked Herminia Guinit, resulting in her death due to injuries inflicted.
Prosecution's Evidence
The prosecution's case heavily relied on the eyewitness account of Victor Guinit, who identified Cabato as one of the assailants. Victor testified that he recognized Cabato when the mask he was wearing fell during a struggle and that Cabato struck his wife with a stone, leading to her death.
Defense's Position
The accused denied involvement in the crime, asserting an alibi that he was gathering corn at a farm a significant distance away at the time of the incident. He testified that he returned home only after the robbery had occurred and claimed not to have known about the crime until informed by neighbors.
Trial Court's Findings
The Trial Court examined the evidence and found that Cabato was positively identified as one of the perpetrators. The court noted that two kerosene lamps illuminated the Guinit home, making it possible for Victor to clearly see the accused. Furthermore, the court rejected the defense's alibi, finding it uncorroborated and weak compared to the eyewitness testimony.
Credibility of Witnesses
The Trial Court gave significant weight to Victor’s testimony, rejecting arguments concerning inconsistencies. The court noted that minor discrepancies in testimony were not detrimental to its overall credibility. The court maintained that these inconsistencies could be attributed to the stress of the situation rather than any effort to fabricate evidence.
Alibi Defense
Cabato's defense hinged on an uncorroborated alibi, which the court deemed less reliable given the direct testimony from Victor. The court underscored that an alibi is typically a weak defense, particularly when contradicted by clear identification from a witness.
Aggravating Circumstances
The prosecution argued for the presence of aggravating circumstances such as treachery, evident premeditation, and dwelling since the crime occurred inside the victims' home. The court agreed on the agg
...continue readingCase Syllabus (G.R. No. L-37400)
Case Overview
- Accused-appellant Sabangan Cabato appeals from the judgment of the Court of First Instance (now Regional Trial Court) of Zamboanga del Norte, which found him guilty of ROBBERY WITH HOMICIDE in Criminal Case No. 307.
- The incident occurred on January 25, 1971, and involved the robbery and homicide of Herminia Am-es Guinit.
Charges and Allegations
- The information filed against Sabangan Cabato on February 12, 1971, details the crime of robbery with homicide, claiming that he, along with two others, armed and intent on illicit gain, unlawfully entered the dwelling of Victor Guinit.
- The accusations include violence against Victor and Herminia Guinit, resulting in the death of Herminia due to injuries inflicted by stones.
Prosecution's Evidence
- Victor Guinit, the sole eyewitness, testified about the events of the crime, providing a detailed account of the armed robbery that took place in his home.
- He identified Sabangan Cabato as one of the assailants after a mask covering Cabato's face fell during a struggle.
- The prosecution relied on Victor's testimony, illustrating the sequence of events and the identification of the accused during the crime.