Case Summary (G.R. No. 125383)
Charges and Incident Description
The Information section filed by the Assistant City Prosecutor indicated that on July 29, 1991, the accused actively conspired to commit robbery against the victim, which resulted in the fatal stabbing of Peregrino. The crime was characterized by malice and intent to kill, as evidenced by multiple stab wounds, leading to the victim's death shortly after the attack.
Medical Findings and Evidence
The medico-legal report by Dr. Florante Baltazar detailed the nature of the stab wounds sustained by the victim, highlighting injuries to the thoracic aorta and other vital areas, concluding that the cause of death was cardio-respiratory arrest due to shock and hemorrhage from these stab wounds. A bloodied knife and the victim's wallet, which contained cash and the victim's driver’s license, were found in possession of the accused, forming critical evidence in the case.
Defense and Testimonies
The accused-appellants presented a defense of denial and alibi, alleging they were manhandled by barangay officials and coerced into confessing the crime. However, several eyewitnesses, including taxi drivers Antonio Bautista and Rogelio Miranda, testified that they witnessed the commotion outside a taxi and identified the accused as the perpetrators of the robbery. These eyewitness accounts were supported by the barangay tanods who apprehended each accused shortly after the incident.
Judicial Findings and Proceedings
The Regional Trial Court found both accused guilty as co-principals of Robbery with Homicide under Article 294 (1) of the Revised Penal Code and sentenced them accordingly to reclusion perpetua. The trial court ruled against the accused's claims and maintained that procedural due process had been observed, rejecting their arguments regarding the absence of preliminary investigation as irrelevant given their prior arraignment and plea.
Appellants' Claims of Error
On appeal, the accused-appellants raised several points of error pertaining to the trial court's rulings, contesting the exclusion of preliminary investigation, the credibility of eyewitnesses, and the alleged improbability of identification given the conditions at the scene. However, the Court emphasized the overall strength of the circumstantial evidence against the accused and affirmed the trial court's findings.
Analysis of Credibility and Evidence
The Supreme Court noted that the trial court's evaluation of witness credibility is critical due to its firsthand observation of their demeanor. The presence of favorable conditions for visibility and corrobo
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Case Overview
- The case revolves around the appeal of accused-appellants Elmer De Asis y Meneses and Danilo Mercado y Adorable against the Decision of the Regional Trial Court, Branch 89 of Quezon City.
- The trial court found both accused guilty beyond reasonable doubt of Robbery with Homicide, as defined under Article 294 (1) of the Revised Penal Code.
- The incident occurred on July 29, 1991, in Quezon City, where the victim, Victor Peregrino y Birangke, was robbed and subsequently murdered.
Facts of the Case
- On the night of July 29, 1991, at approximately 1:40 AM, taxi drivers Antonio Bautista and Rogelio Miranda were eating at a restaurant when they heard shouts of "hold-up" from a nearby taxi.
- They observed two men exiting the taxi, one of whom was identified as Danilo Mercado, who was armed with a fan knife.
- The accused threatened the witnesses, prompting them to flee while the two men ran away in the direction of Manila.
- A chase ensued, during which Mercado was apprehended by barangay tanod Rodrigo Austero, who recovered a blood-stained knife from him.
- Elmer De Asis was caught shortly afterward by barangay tanod Mariano Perez, who found a wallet containing P350.00 and the victim's driver's license in De Asis's possession.
Medical Findings
- The medico-legal repor