Case Summary (G.R. No. 105992)
Incident Details
On August 27, 1989, the victims were attacked in their bedroom during the early morning hours. Glerissa heard knocking at the door and, upon opening it, encountered the three accused whom she recognized. Armed with iron bars, they forcibly pulled her out of the room, locked the door, and subsequently attacked the Lim spouses, causing their deaths. Evidence suggests robbery was the motive, with cash and jewelry stolen from the victims' residence.
Trial and Charges
The Regional Trial Court of Kalookan City charged the accused with robbery with double homicide under Criminal Case No. C-33866. The prosecution's main evidence came from Glerissa, whose testimony outlined the sequence of events leading to the victims’ deaths.
Accused's Defense
Rolando Cabrera, the accused-appellant, denied participation, claiming he was coerced by his co-accused under threat of violence. He asserted that he did not share a motive for the crime unlike his co-accused, who had been cursed by the victims over a salary issue. Cabrera contended that he did not have the opportunity to report the crime due to fear and allegedly being monitored by his accomplices.
Circumstantial Evidence and Conspiracy
The appellate court noted the reliance on circumstantial evidence, as no witness directly observed the crime. The court held that circumstantial evidence, when considered collectively, established the guilt of Cabrera. The conspiracy was inferred from the coordinated actions of all three accused before, during, and after the commission of the crime. The trial court's determination that a conspiracy existed was upheld, indicating that the actions of the accused sufficed to demonstrate their collective criminal intent.
Witness Credibility and Conduct
The court found Glerissa's testimony credible despite her fear-induced actions during the incident. Her age and vulnerability were taken into account, suggesting that her response was consistent with someone under threat. The presence of the two steel bars further corroborated the prosecution's case.
Sentencing and Legal Considerations
The trial court convicted Cabrera of double homicide and imposed a penalty of reclusion perpetua. However, the appellate court modified this sentence, stating that the crime did not warrant such a severe penalty under the Revised Penal Code. The court reasoned that since homicide does not equat
...continue readingCase Syllabus (G.R. No. 105992)
Case Overview
- This case involves the conviction of Rolando Cabrera and his co-accused for robbery with double homicide.
- The incident occurred on August 27, 1989, when the spouses Wilfredo Chua Lim and Libby Teng de Lim were attacked in their bedroom.
- The prosecution presented evidence through Glerissa Piamonte, a babysitter in the Lim household, who witnessed the events leading to the couple's demise.
Charges and Allegations
- Cabrera, along with co-accused Roland Sungkip and Alandino Capareno, was charged with robbery with double homicide.
- The information alleged that the accused conspired to commit robbery and inflicted serious injuries on the victims, resulting in their deaths.
- The specific items taken included P10,000 in cash and jewelry valued at P30,000 belonging to the Lim spouses.
Witness Testimony
- Glerissa Piamonte testified that on the night of the incident, she was sleeping with the Lim couple's one-year-old son.
- At approximately 2:15 AM, she opened the door to find the three accused, who she recognized as they were known to her.
- The accused were armed with steel bars, and Cabrera threatened Glerissa, pulling her from the room and causing her to lose consciousness.
- After regaining consciousness, Glerissa heard sounds from the bedroom and later found the Lim spouses dead upon checking.
Accused's Defense
- Cabrera claimed he was coerced into participating in the crime under threat from his co-accused, who allegedly brandished a blood-stained knife.
- He maintained that he did not have any motive to harm his employers and was unaware of th