Case Summary (G.R. No. 197546)
Charges and Initial Proceedings
The accused-appellants were charged with Robbery with Homicide under an Information alleging that on March 2, 2002, they conspired to rob Emilio A. Prasmo, resulting in his death through violent means. Despite the pleas of not guilty from most of the accused, the Regional Trial Court (RTC) conducted a trial with the prosecution presenting testimonies that outlined a brutal attack on the victim, resulting in grievous injuries leading to his death.
Evidence of the Prosecution
Erlinda Prasmo testified that while walking with her husband, the accused-appellants blocked their way and attacked Emilio violently with various weapons, including a sumpak and lead pipes, before robbing him of P7,000. Despite her calls for help, the presence of Bayani brandishing a gun deterred any bystanders from intervening. Medical evidence corroborated the violence and the fatal wounds sustained by Emilio.
Evidence of the Defense
The defense presented testimonies asserting that the accused-appellants were victims of a prior attack by Emilio and his family the night before, claiming they acted in self-defense during the encounter. However, their alibis and assertions of self-defense were undermined by inconsistencies in their narratives and the overwhelming evidence of a premeditated attack.
Ruling of the Regional Trial Court
The RTC found the prosecution's evidence credible and determined that, instead of robbery with homicide, the accused-appellants were guilty of Murder, ruling out robbery due to insufficient proof. It highlighted the presence of treachery and abuse of superior strength in the manner of the attack, emphasizing that the actions demonstrated a clear intent to kill. Consequently, all accused-appellants were sentenced to reclusion perpetua and ordered to indemnify the victim's heirs.
Ruling of the Court of Appeals
The Court of Appeals affirmed the RTC's decision, emphasizing the credibility of Erlinda's account despite minor inconsistencies and reiterating the premeditated nature of the crime. While the appellate court maintained the Murder conviction, it modified the ruling regarding Danilo's actions, determining he was guilty of Robbery for taking the victim's money during the incident.
Assignment of Errors
The accused-appellants challenged the appellate court's ruling, arguing that it wrongly credited Erlinda's inconsistent testimony and disregarded their self-defense claims. However, the appellate court found Erlinda's testimony to be largely credible and consistent with the physical evidence.
Ruling on Self-Defense
In addressing the self-defense claim, the court ruled that the accused-appellants failed to establish the elements necessary to substantiate such a claim. The actions of the victim did not amount to unlawful aggression or justify the deadly response by the accused.
Double Jeopardy Analysis
The court identified a possible double jeopardy issue regard
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Case Overview
- The case involves the conviction of accused-appellants Bayani De Leon, Antonio De Leon, Danilo De Leon, and Yoyong De Leon for the crime of Murder, initially charged as Robbery with Homicide.
- The Regional Trial Court (RTC) delivered a conviction that was later affirmed with modifications by the Court of Appeals.
Facts of the Case
- On March 2, 2002, in Quezon City, the accused-appellants allegedly conspired to rob Emilio A. Prasmo while he was walking with his family.
- Armed with various weapons, including a sumpak (homemade firearm), samurai (sword), and lead pipes, the accused attacked and inflicted serious injuries on Emilio, resulting in his death.
- The robbery involved the taking of P7,000.00 from Emilio.
Charges and Arraignment
- The accused were charged with Robbery with Homicide under an Information detailing the violent attack.
- Upon arraignment, all accused-appellants entered a plea of not guilty, except for Antonio, leading to a reverse trial for him.
Evidence Presented
Prosecution's Evidence
- Erlinda Prasmo, the victim's wife, provided eyewitness testimony detailing the assault by the accused.
- Erlinda described how Danilo struck Emilio with a sumpak, while Antonio and Yoyong also attacked him with deadly weapons.
- Testimony from Gina Prasmo (Emilio’s daughter) and a medico-legal report documented Emilio's injuries and subsequent death.
Defense's Evidence
- The defense argued that