Case Summary (G.R. No. 118670)
Charge and Initial Proceedings
The Information filed against the accused on January 26, 1993, alleged that they conspired to rob the Belmontes and, in the process, committed homicide. Upon arraignment, de Guzman, Ramos, and Mosqueda pleaded not guilty to the charges. Mosqueda was later discharged from the case and testified for the prosecution, leading to the eventual convictions of de Guzman and Ramos on December 21, 1994.
Trial Court's Decision
The Regional Trial Court found both de Guzman and Ramos guilty beyond a reasonable doubt of robbery with homicide. They were sentenced to reclusion perpetua and liable for civil damages to the heirs of the victims, which included restitution of stolen items, indemnification for lost earnings, and various forms of damages.
Appeal Process
De Guzman later withdrew his appeal, leaving Ramos as the sole appellant in this case. Ramos contested the trial court's ruling, arguing primarily that the discharge of Mosqueda as a state witness was erroneous and that the prosecution failed to prove his guilt beyond a reasonable doubt.
Discharge of State Witness
The Supreme Court examined the criteria for an accused's discharge to become a state witness as outlined in the Rules of Court. Although the Court acknowledged that some requirements were not strictly adhered to, it concluded that the testimony of Mosqueda could still be considered credible. The Court noted that the discharge of a co-accused does not impact the validity of their testimony against the remaining accused.
Evidence and Interpretation
Ramos contended that the testimonies presented by the prosecution were circumstantial and insufficient for a conviction. However, the Court found no compelling reason to question the trial court's assessment of witness credibility. Mosqueda's testimony was deemed sincere and detailed, which further affirmed its reliability in corroborating the prosecution's case against Ramos.
Defense of Alibi
Ramos presented an alibi claiming he was on duty as a police officer in Pozorrubio, Pangasinan, during the commission of the crime. However, the prosecution successfully rebutted this alibi with evidence showing Ramos was not at the police station at the critical time and could have easily traveled to Baguio. Therefore, the defense of alibi was deemed insufficient to exonerate him.
Application of Legal Provisions
The Supreme Court ruled that under Article 294 of the Revised Penal Code, the correct penalty was reclusion perpetua. The Court concurred with the trial court's findings of aggravating circumstances but clarified the penalty following the legislative proscription of the death penalty at the
...continue readingCase Syllabus (G.R. No. 118670)
Case Background
- The case involves Renato De Guzman, Marciano Ramos, Frederick Mosqueda, and Paquito Ancheta, who were charged with robbery with homicide before the Regional Trial Court of Baguio City.
- The charge stems from an incident on December 2, 1992, where the accused allegedly conspired to rob Dr. Amadeo Belmonte and his wife, resulting in the victims' deaths.
- The total value of the stolen items was approximately P325,650.00, including cash and various personal belongings.
Proceedings in Trial Court
- Upon arraignment, De Guzman, Ramos, and Mosqueda pleaded "not guilty."
- Mosqueda was later discharged and became a state witness for the prosecution.
- On December 21, 1994, the trial court convicted De Guzman and Ramos of robbery with homicide, sentencing them to reclusion perpetua.
Accused's Appeal
- Dissatisfied with the verdict, De Guzman and Ramos appealed the decision. However, De Guzman later withdrew his appeal, leaving only Ramos's appeal for resolution.
- The trial court's findings included that De Guzman and Mosqueda initially approached the Belmontes under the pretense of delivering a water tank, but their actual intent was to rob and kill them.
Facts Leading to the Crime
- The Belmontes had previously hired De Guzman to construct a water tank but became dissatisfied with his work.
- After a drinking session, De Guzman, along with his accomplices, plotted to break into the Belmonte home.
- On the night of the crime, the Belmontes’ house was left with only their househelpers present.