Case Summary (G.R. No. 138516-17)
Procedural Background
Emma dela Cruz appeals the January 22, 1999 Decision of the Regional Trial Court (RTC) of Quezon City, which convicted her and Roger Liad of robbery with homicide. They were sentenced to reclusion perpetua and ordered to pay moral, actual, and exemplary damages to the victims’ heirs, totaling approximately P416,957.
Charges Against the Accused
On January 1, 1999, an Information was filed against Roger Liad for robbery with homicide, followed by a second Information charging Emma dela Cruz and two others with the same crime. The accusations detail that they conspired to rob the residence of Norma Lozano at knifepoint and fatally attacked her and her daughter.
The Prosecution's Case
The prosecution presented evidence demonstrating that Emma dela Cruz was employed as a maid by the victim. Significant events leading to the crime included a Christmas break taken by Emma and her sister, Riza, and Emma's suspicious return to the victims’ house shortly before the attack. Witnesses testified they observed Emma and Roger emanating from the crime scene around the time of the murders, and police investigation corroborated the timeline of events, alongside forensic evidence detailing the nature of the victims' injuries.
The Defense's Argument
In contrast, Emma claimed she had left for her hometown before the incident and denied involvement. She alleged the police coerced her into implicating Roger Liad, asserting the prosecution's witnesses were unreliable. Her claims were met with skepticism due to the circumstantial evidence linking her to the crime and her failure to provide a credible alibi corroborated by independent witnesses.
Trial Court's Findings
The trial court concluded that circumstantial evidence showcased culpability, affirming the presence of conspiracy among the accused, inferred from their collective actions leading to the commission of the crime. The decision highlighted that circumstantial evidence can establish guilt beyond a reasonable doubt, especially when it forms an unbroken chain directing to the accused.
Issues and Court's Ruling
The appellant raised issues on the credibility of witnesses and the finding of conspiracy. The Supreme Court found no merit in her appeal, emphasizing the consistency of the witnesses' testimonies, despite some alleged minor discrepancies. The evidence, even circumstantial in nature, adequa
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Case Overview
- The case involves the appeal of Emma Dela Cruz against the decision of the Regional Trial Court (RTC) of Quezon City, which convicted her and Roger Liad of robbery with homicide.
- The RTC sentenced both accused to reclusion perpetua, ordered them to pay actual, moral, exemplary damages, and indemnity for the death of the victims.
Background of the Case
- An Information was filed against Roger Liad for robbery with homicide on January 1, 1999.
- A subsequent Information charged Emma Dela Cruz and two others with the same crime, detailing the robbery of Norma Lozano's residence and the murder of Lozano and her daughter Lorgiza.
The Incident
- On December 27, 1994, the accused allegedly entered the residence of Norma Lozano, robbed her at knife point, and inflicted fatal stab wounds on both her and her daughter.
- The crime scene was described as chaotic, with the apartment ransacked, and the victims found lifeless in the bathroom.
Prosecution's Version
- Ma. Lourdes Velasco, the private complainant, hired Emma Dela Cruz as a maid in September 1994.
- Dela Cruz, along with her sister, had requested time off during the holidays but returned on December 25, 1994.
- On December 27, Velasco discovered the crime scene upon return