Case Summary (A.M. No. 20-07-10-SC)
Procedural History
Respondent was charged with robbery with homicide (Article 294(1) RPC). At arraignment he pleaded not guilty. The RTC convicted him of the special complex crime and imposed reclusion perpetua without parole, plus P300,000 in damages. The Court of Appeals affirmed, admitting circumstantial and admission-against-interest evidence. Respondent appealed to the Supreme Court.
Prosecution’s Evidence
- Security guard logbook entries and in-court identification by Koh.
- Classmates’ discovery of the victim’s body and blood-spattered crime scene photographs.
- Testimony of Mark Adalid detailing respondent’s voluntary confession during a drinking spree, including motive (payment dispute) and acts (stabbing, theft, disposal of evidence).
- NBI recovery of the 9.5-inch knife from the victim’s toilet drainage.
- Medico-legal report confirming 25 stab wounds, three fatal, by a sharp instrument.
- Text-message operations orchestrated by victim’s brother to trace respondent via aliases “Enzo” and “Sheryl.”
Defense’s Position
Respondent denied the charges, claiming an alibi of selling barbecue with his partner. He attacked Koh’s logbook credibility (no original offered, improbable 24-hour duty, inconsistent security procedures) and characterized Mark’s testimony as inadmissible hearsay. No stolen items were recovered from him.
RTC Findings
The trial court found all elements of robbery with homicide satisfied: unlawful taking with intent to gain, violence resulting in death. It credited the circumstantial evidence as an unbroken chain despite lack of eyewitnesses. Aggravating circumstances (treachery, premeditation, abuse of superior strength) were not proven.
Court of Appeals Ruling
The appellate court affirmed. It held: (a) the Information clearly charged the complex crime; (b) circumstantial evidence and Koh’s in-court identification established guilt beyond reasonable doubt; and (c) Mark’s testimony was non-hearsay as an independently relevant statement.
Issue on Appeal
Whether respondent committed the special complex crime of robbery with homicide under Article 294(1) RPC.
Admission Against Interest and Hearsay Analysis
The Supreme Court rejected the classification of Mark’s testimony as an independently relevant statement. It applied Section 27, Rule 130, Rules of Court, recognizing respondent’s detailed confession to Mark as an admission against interest (a party’s own out-of-court declaration). Admissions against interest are admissible despite hearsay prohibitions when:
(a) they involve matters of fact;
(b) are categorical and definite;
(c) made knowingly and voluntarily; and
(d) adverse to the declarant’s interest.
Complex Crime Versus Separate Offenses
Robbery with homicide requires proof that the intent to rob preceded the killing (“robbery is the central purpose”). Here, evidence showed that respondent killed the victim first (motivated by anger over underpayment) and then took belongings as an
Case Syllabus (A.M. No. 20-07-10-SC)
Facts
- On September 24, 2007 at around 6:00 p.m., appellant Edgardo Catacutan y Mortera (aliases “Batibot,” “Enzo,” and “Gerry”) visited the rented unit of Alexander Tan Ngo at PND Apartelle, Quezon City.
- Appellant identified himself as “Gerry” but failed to show proof of identity; security guard Alfredo Ortiz Koh escorted him to Alexander’s door, where Alexander acknowledged him.
- Appellant and Alexander allegedly had sexual intercourse; when Alexander fell asleep, appellant armed himself with a kitchen knife and stabbed the victim repeatedly, slashed his neck to ensure death, then stole various personal items.
- Stolen items included a Philips portable DVD player, Sony Ericsson cellphone, Fossil watch, Creative ZEN multimedia player, Sony Cyber-Shot digital camera, photo iPod, bracelet, and cash.
- Alexander’s body was discovered on September 25, 2007 by classmates who found the door unlocked, saw blood inside, and called the police.
Procedural History
- Criminal Case No. Q-08-153138 was filed before the RTC of Quezon City, Branch 101, charging appellant with robbery with homicide (RPC Articles 294(1) and 293).
- By Amended Decision dated June 29, 2018, the RTC found appellant guilty of robbery with homicide and sentenced him to reclusion perpetua without eligibility for parole, plus civil, moral, and exemplary damages.
- Appellant appealed to the Court of Appeals.
- On January 26, 2021, the CA in CA-G.R. CR-HC No. 11631 affirmed the RTC decision.
- Appellant filed a petition for review on certiorari under G.R. No. 260731 before the Supreme Court.
Prosecution’s Evidence
- Security Guard Alfredo Ortiz Koh
- Logged appellant’s arrival on September 24 at 6:00 p.m. and departure on September 25 at 6:05 a.m.; identified him in court and in photographs.
- Classmate Robert John Ramos and companions
- Noticed Alexander’s absence from school, discovered his body in the unit, and assisted police by identifying the crime scene.
- Witness Mark P. Adalid
- Testified that appellant narrated, during a drinking spree, the stabbing and robbery of Alexander; identified the silver Sony Cyber-Shot digicam and its photos.
- NBI Agent Valiant Raganit
- Recovered a 9.5-inch knife from Alexander’s comfort room