Case Summary (G.R. No. 223103)
Key Dates
January 3, 2002 – Commission of robbery with homicide and frustrated homicide
April 15, 2011 – RTC Decision convicting appellants
March 25, 2015 – CA Decision affirming with modification
February 24, 2020 – Supreme Court Decision
Applicable Law
1987 Philippine Constitution; Revised Penal Code, Article 294 (robbery with homicide), Article 48 (complex crimes); Republic Act No. 9346 (proscribing death penalty); relevant jurisprudence (People v. Baron, People v. Tidong, People v. Jugueta)
Factual Background
On January 3, 2002 at about 7:30 p.m., five armed men forcibly entered the Padre family residence in Villaruz, Delfin Albano. They threatened Manuel and Nenita Padre and their daughters, Rhoda and Rachelle. Labuguen dragged Rachelle into a comfort room; other assailants separated family members. Labuguen stabbed and attempted to strangle Rachelle, who feigned death and escaped. Meanwhile, Zuniga and others inflicted fatal wounds on Manuel, Nenita, and Rhoda using firearms and bladed weapons. The perpetrators fled with ₱500,000. Rachelle survived due to timely medical treatment; the three others died. Labuguen was arrested January 4, 2002; Zuniga was apprehended in 2006.
Procedural History
The Regional Trial Court of Cabagan, Isabela, Branch 22, found appellants guilty beyond reasonable doubt of robbery with homicide and frustrated homicide. Each was sentenced to reclusion perpetua and ordered to pay actual and civil indemnity damages. The Court of Appeals affirmed the conviction but modified civil indemnities to ₱75,000 per victim. The People appealed to the Supreme Court.
Issues on Appeal
- Whether appellant Zuniga may invoke the exempting circumstance of irresistible force or uncontrollable fear.
- Whether Rachelle’s identification of the assailants is credible.
- Whether conspiracy was sufficiently established.
- Proper characterization of offenses and appropriate penalties and damages.
Ruling on Exempting Circumstance
The Court held that Zuniga cannot avail of uncontrollable fear. Exempting force requires a real, imminent threat leaving no opportunity to escape. Evidence showed Zuniga was a knowing, active participant in a well-planned crime, had opportunities to flee through cornfields, and performed overt acts of violence without coercion.
Credibility of Identification
Challenges to Rachelle’s testimony were rejected. Her delay in naming assailants was reasonably attributed to trauma and uncertainty about whom to trust. She eventually positively identified Labuguen and Macalinao, and later Zuniga, before fiscal investigators.
Existence of Conspiracy
Conspiracy was established by proof of common design: meeting at a prearranged location, proceeding in concert to the Padre residence masked and armed, committing violence to facilitate robbery, and reuniting afterward to divide the loot. All conspirators acted to achieve their shared criminal objective.
Elements of Robbery with Homicide and Frustrated Homicide
Robbery with homicide requires (1) taking of another’s property with intent to gain, (2) use of violence or intimidation, and (3) homicide occurring by reason of or on the occasion of the robbery. Frustrat
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Facts of the Case
- On the evening of January 3, 2002, five armed men forcibly entered the home of spouses Manuel and Nenita Padre in Villaruz, Delfin Albano, Isabela, while the family dined with their daughters, Rhoda and Rachel.
- The intruders were armed with a firearm and bladed instruments; one wore a bonnet with a single eye‐hole.
- Labuguen led the assault on Rachel, pulling her into the comfort room, later stabbing her in the chest, striking her forehead with the butt of a gun, and strangling her until she feigned death.
- Simultaneously, Zuniga and another assailant attacked Manuel and Nenita in the store behind the house: Manuel was struck on the head; Nenita was boxed in the abdomen and stabbed in the back.
- Rhoda attempted to flee but was shot by an associate; all three—Manuel, Nenita, and Rhoda—sustained fatal injuries and died that night.
- Believing the entire family dead, the assailants fled to Joel Albano’s home, divided a P500,000 take, and then dispersed; Zuniga went into hiding in Tarlac until his 2006 arrest.
- Rachel was rescued, treated for serious chest wounds and head and neck injuries, and released from the hospital on January 12, 2002.
- Law enforcement identified Labuguen through a blood‐stained jacket testing positive for human blood group A and apprehended him on January 4, 2002. Rachel later identified both Labuguen and Macalinao; Zuniga surrendered following police investigation.
Procedural History
- Regional Trial Court (Cabagan, Branch 22) Decision (April 15, 2011): Convicted Labuguen and Zuniga of Robbery with Homicide and Frustrated Homicide; imposed reclusion perpetua each and awarded civil indemnity to Rachel Padre and the estates of the deceased.
- Notice of Appeal filed; Macalinao remained at large, warrant issued; Peter Doe and John Doe cases archived pending identification.
- Court of Appeals Decision (March 25, 2015): Affirmed RTC conviction of robbery with homicide but modified damages award; ordered appellants to pay Rachel Padre P75,000 as civil indemnity per victim.
- Supreme Court Appeal: Parties filed manifestations i