Case Summary (G.R. No. 115401)
Facts of the Case
On the night of August 24, 1992, Edilberto Fabula and his accomplices violently attacked and killed Mariano and Petra Cueto. Witness Bernardo Lingasa provided critical testimony that he witnessed Fabula stab Petra and that Mariano was subsequently attacked when he attempted to help his wife. The prosecution also introduced evidence of stolen funds. The sum of P15,000 was localized to the Cueto’s store through testimony from their son, Danilo Cueto, indicating that he had seen his mother counting the money prior to the incident.
Charge and Proceedings
The accused were charged with Robbery with Double Homicide under Article 294, paragraph 1 of the Revised Penal Code. Only Edilberto Fabula stood trial since the other accused were not apprehended. The trial court ultimately convicted Fabula and sentenced him to two terms of reclusion perpetua for the deaths of the Cueto spouses, along with a monetary indemnity to be paid to their heirs.
Defense and Appeal
In his appeal, Fabula claimed the prosecution had manipulated the facts and alleged that witnesses were inconsistent. The appeal argued that the trial court made errors regarding the evidence and the credibility of the witnesses. However, the Appellate Court noted that Fabula's brief failed to comply with the procedural requirements, including a failure to provide a subject index and a statement of errors.
Judicial Analysis
The Appellate Court examined the credibility of the eyewitness testimony, reaffirming that Lingasa’s identification was clear and direct. The Court found no compelling reason to question the trial court's conclusions regarding witness credibility. Furthermore, the accused's alibi was weakened by the lack of corroborative evidence, failing to establish that it was impossible for him to be at the crime scene at the time of the killings.
Error in Sentencing
The court acknowledged a substantive legal error in the trial court's sentencing. Robbery with Double Homicide, as charged, is not recognized as an offense under the Revised Penal Code; rather, the law addresses robbery with homici
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Case Overview
- The case involves the crimes of robbery and double homicide committed on August 24, 1992, in Barangay Gamao, Naujan, Oriental Mindoro.
- The accused named in the case are Edilberto Fabula (alias Eden), Kano Fabula, Ricky Cusi, and an unidentified John Doe.
- The case was brought before the Regional Trial Court of Calapan, Oriental Mindoro, where Edilberto "Eden" Fabula was the only accused arraigned and tried, as the others were at large.
Incident Details
- On the evening of the incident, around 8:00 PM, an elderly couple, Mariano Cueto and Petra Cueto, were robbed and killed near their home.
- The prosecution's information stated that the accused acted with intent to gain, using force and intimidation to steal P15,000 from the victims.
- During the robbery, the accused attacked and stabbed the couple multiple times, leading to their instantaneous deaths.
Prosecution's Evidence
- The prosecution presented eyewitness Bernardo Lingasa, who testified that he witnessed the incident.
- Lingasa heard Petra Cueto scream and saw Edilberto "Eden" Fabula stab her. Mariano Cueto rushed to help his wife but was also attacked and stabbed.
- Lingasa recounted that Fabula instructed his companion to leave, declaring the victims were dead.
- To corroborate the robbery aspect, Danilo Cueto, the son of the victims, testi