Title
People vs. Lacatan
Case
G.R. No. 121532
Decision Date
Sep 7, 1998
Three accused robbed and killed Alfredo Salazar, stabbing him multiple times; eyewitness testimony and evidence led to their conviction for Robbery with Homicide.
A

Case Summary (G.R. No. 121532)

Relevant Facts

On the evening of November 23, 1990, the accused, while armed with bladed instruments, conspired to commit robbery against Alfredo Salazar. The Information filed by the Assistant Provincial Prosecutor alleged that they unlawfully took P100,000 in cash, P50,000 worth of jewelry, and P20,000 worth of assorted foodstuffs amid a violent attack that resulted in the death of the victim due to multiple stab wounds.

Prosecution Evidence

Witness Eduardo Ruallo, who witnessed the crime, testified that he saw the accused physically restraining Alfredo Salazar while Rommel Lacatan stabbed him multiple times. Witnesses Elmer Salazar and Edna Salazar, children of the victim, found their father's body after entering the dark house, confirming that a robbery had taken place, with valuables missing. Anicia Salazar, the victim's widow, provided corroborative testimony regarding the financial impact of the robbery and murder on their family, while the medical examination conducted by Dr. Edgardo Hernandez indicated that the victim suffered nine stab wounds and five incise wounds, pointing to the use of multiple weapons.

Defense Strategy

The defense relied on alibi, claiming that the appellants were engaged in activities separate from the crime at the time it occurred. Each accused presented testimony about their whereabouts, stating they were drinking or conducting personal affairs away from the scene. Defense witnesses attempted to cast doubt on the credibility of the prosecution's eyewitness, Eduardo Ruallo, citing inconsistencies.

Ruling by the Trial Court

The Regional Trial Court found the evidence presented by the prosecution credible and convicted the appellants of robbery with homicide, stressing the presence of aggravating circumstances such as evident premeditation and cruelty. Each accused was sentenced to suffer reclusion perpetua and ordered to indemnify the heirs of the victim for losses incurred due to the crime.

Appellate Review

On appeal, the accused challenged the trial court's credibility assessment of the witnesses and the sufficiency of evidence against them. However, the appellate court reiterated that it generally defers to the trial court’s j

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