Case Summary (G.R. No. L-42964)
Charges and Details of the Crime
The accused were charged with the complex crime of robbery with homicide under Article 294, paragraph 1 of the Revised Penal Code. The information alleged that the accused conspired to rob and kill Anselmo Rollorata, exploiting the nighttime and their superior strength. They forcibly entered Rollorata's home, shot him, and stole cash and personal belongings valued at P1,799.50.
Procedural History
Following their arraignment, all accused pleaded not guilty, and the trial proceeded. On November 3, 1975, the court convicted Escabarte, Sygaco, and Tome, sentencing each to reclusion perpetua, together with fines for the indemnification of the victim's heirs, leading to the appeal by the accused.
Appellants' Assigned Errors
The appellants raised multiple assigned errors on appeal, contesting the trial court's credibility assessments regarding the prosecution and defense witnesses, the admissibility of an extrajudicial confession made by Lauro Tome, and the sufficiency of evidence establishing guilt beyond a reasonable doubt. They specifically challenged the testimonies of Juana and Ricardo Rollorata, the wife and son of the victim, and their identification of the accused.
Credibility of Witnesses
The appellant's argument focused primarily on alleged inconsistencies and improbabilities in the testimonies of the prosecution witnesses. For instance, Juana claimed to have seen four robbers while Ricardo mentioned only three; discrepancies in their positions during the crime were highlighted. Despite these claims, the trial court found the eyewitness testimonies to be credible and consistent, emphasizing the trial court's discretion in determining witness credibility, which is generally respected on appeal.
Defense of Alibi
The appellants presented an alibi defense, asserting they were not present at the crime scene at the time of the incident. Francisco Escabarte claimed he was in Sapang Dalaga, corroborated by local authorities; Gregorio Sygaco claimed he was asleep elsewhere; and Lauro Tome was said to be at home. The court dismissed the alibi since the distance between the accused's claims and the location of the crime did not make their presence at the scene impossible. Furthermore, eyewitness identification outweighed their alibi assertions.
Admissibility of Extrajudicial Confession
The appellants contested the admissibility of Lauro Tome's extrajudicial confession, claiming it was obtained without legal counsel and under duress. The court found that sufficient evidence existed for conviction independent of this confession. The admission of this confession did not change the overall sufficiency of the prosecution's case against the accused.
Aggravating Circumstances
The appellate court analyzed the aggravating circumstances cited in the information: evident premeditation, advantage of superior strength, use of firearms, and commission by a band. The court found that evidence established these ci
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Case Overview
- This case concerns the complex crime of robbery with homicide, committed on May 31, 1973, in barrio Kausuagan, Plaridel, Misamis Occidental.
- The accused, Francisco Escabarte (alias Boy), Gregorio Sygaco (alias Korak), and Lauro Tome, were charged with conspiring to rob Anselmo Rollorata and subsequently killing him.
- The trial court found the accused guilty beyond reasonable doubt, sentencing them to reclusion perpetua and the obligation to indemnify the heirs of the victim.
Charge Details
- The information filed against the accused included the following allegations:
- Conspiracy to commit robbery and homicide.
- The accused took advantage of nighttime and their superior strength to break into the victim's home.
- Upon entry, they unlawfully shot Anselmo Rollorata in the back, resulting in his death.
- Stolen items included cash (P1,200), a .22 caliber rifle (P300), a wristwatch (P280), and a flashlight (P19.50), totaling P1,799.50 in damages.
Trial Proceedings
- The trial commenced with the arraignment of the accused, all pleading not guilty.
- Silas Paredes was dismissed from the case due to insufficient evidence.
- On November 3, 1975, the trial court rendered a decision convicting the accused.
Appeals and Errors Assigned
- The accused appealed, alleging multiple errors by the trial court:
- Credibility of prosecution eyewitnesses Juana and Ricardo Rollorata.
- Rejection of their defense.
- Admission of Lauro Tome's extrajudicial confession.
- The finding of guilt beyond reasonable doubt.