Case Summary (G.R. No. 103497)
Original Charge and Trial Proceedings
Diosdado Domondon and Roberto Bulalayao were charged with Robbery with Homicide following an incident in which they allegedly conspired to rob passengers in a jeepney, resulting in the stabbing death of Jaime Lim. Upon arraignment, both accused pleaded not guilty. After a trial, the court found both guilty beyond reasonable doubt, sentencing them to life imprisonment and requiring them to pay damages to the heirs of Jaime Lim amounting to P50,000 and P1,500 as pecuniary damages.
Factual Background
On September 7, 1987, witnesses, including Jaime Lim and his sister Ofelia, were aboard a jeepney when Domondon, armed with a bladed weapon, announced a hold-up. Bulalayao also reportedly had a weapon and threatened passengers. During the robbery attempt, Jaime Lim resisted and was subsequently stabbed by Bulalayao. After the attack, Lim was taken to a hospital but succumbed to his injuries, with the cause of death determined to be severe hemorrhage from the stab wounds.
Defense Strategies
During the trial, both accused presented different defenses. Bulalayao claimed an alibi, stating he was driving a tricycle at the time of the incident. Domondon alleged he was a victim of another hold-up immediately before the jeepney incident, trying to distance himself from the robbery. Notably, Bulalayao later changed his testimony, admitting to committing the crime and indicating Domondon was not involved.
Appellate Review
Diosdado Domondon appealed the trial court's decision, arguing that the prosecution failed to prove the elements of robbery necessary for a conviction for Robbery with Homicide. He requested the court to modify the judgment to reflect a conviction for homicide instead, asserting that since the items stolen were not conclusively identified, the crime constituted an attempted robbery with homicide.
Prosecution's Arguments
The Solicitor General conceded that the evidence for consummated robbery was not sufficiently proven. However, it was argued that Domondon's conduct during the attempted robbery implicates him in an attempted robbery with homicide, as outlined in Article 297 of the Revised Penal Code. The prosecution contended that Domondon’s direct involvement in the perpetration of a violent crime established the requisite intent for a greater offense.
Court's Findings and Legal Principles
The court considered the testimonies of witnesses, the variance between the information filed and concrete evidence, such as the absence of personal belongings taken during the robbery. The decision referenced prior rulings, emphasizing that
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Case Overview
- This case involves the conviction of Diosdado Domondon and Roberto Bulalayao for the crime of Robbery with Homicide.
- The incident occurred on September 17, 1987, in Manila, where the accused allegedly conspired to rob passengers of a jeepney, resulting in the death of Jaime Lim.
- The trial court sentenced both accused to life imprisonment and ordered them to pay damages to the heirs of the victim.
Charges and Initial Proceedings
- Information Filed: The Assistant City Prosecutor of Manila charged the accused with robbery with homicide, detailing the methods used and the property taken.
- Arraignment: Both accused pleaded not guilty to the charges.
- Trial Court Decision: The trial court found both guilty beyond reasonable doubt and imposed a life sentence along with monetary damages.
Factual Background of the Incident
- Events of the Crime:
- The jeepney was hailed by passengers, including Jaime Lim and Rodolfo Ungsod.
- Two men boarded the jeepney as it traveled through Manila, one being Domondon and the other Bulalayao.
- Domondon announced a hold-up while brandishing a weapon, demanding valuables from the passengers.
- A struggle ensued when Jaime Lim resisted, leading to him being stabbed by Bulalayao.
- The accused fled after the commotion, with Lim later succumbing to his injuries.