Case Summary (G.R. No. 266754)
Factual Background
On 2 August 1994, the corpse of Angel Alquiza was discovered in a sack in a flooded area in Manila. The victim had sustained severe injuries indicative of sexual assault and homicide. The key witnesses, including family members and police officers, provided accounts leading to the identification and apprehension of the accused.
Crime Investigation and Evidence
Initial investigations revealed that Angel went missing after she left home to buy food. Eyewitness accounts described her being in the company of a known pedicab driver, Abundio Lagunday, who later implicated the appellants during custodial questioning. Further testimonies indicated that eyewitness Herminia Barlam saw the accused commit the crime, providing a detailed description of the acts committed against the victim.
Medical Findings
The autopsy performed by Dr. Lagat confirmed multiple stab wounds, traumatic injuries, and identified the cause of death as homicide due to the inflicted injuries. Key postmortem findings underscored the brutality of the crime, with extensive lacerations and dismemberment.
Judicial Proceedings
The trial court found Lagarto and Cordero guilty of rape with homicide and initially sentenced them to reclusion perpetua. However, following a motion by the prosecutor, the penalty was amended to death after the appellate court ruled that the trial court had erred in imposing the lesser sentence.
Appeals Raised by Defendants
Both accused filed appeals asserting that:
- There was insufficient evidence linking them to the crime, particularly questioning the credibility of witness testimonies.
- They provided alibis that were not adequately considered.
- The identification made by prosecution witnesses was flawed and not credible.
- They were subjected to illegal arrest and lacked proper preliminary investigation.
Court's Findings and Rulings
The Supreme Court upheld the trial court’s judgment, emphasizing the weight of testimony from Barlam, who was deemed competent despite her disabilities. The court noted that her consistent accounts and the autopsy findings corroborated the prosecution's claims of conspiracy among the accused to commit the heinous acts. The court reiterated that in instances of conspiracy, the actions of any one participant are attributable to all.
Penalty and Civil Liabilities
Given the gravity of the crime and the aggravating circumstance of cruelty, the court affir
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Case Overview
- The case involves the conviction of accused-appellants Henry Lagarto y Petilla (Lagarto) and Ernesto Cordero y Maristela (Cordero) for the rape and murder of seven-year-old Angel Alquiza y Lagman.
- The Regional Trial Court of Manila, Branch 47, under Judge Lorenzo B. Veneracion, initially sentenced the accused to reclusion perpetua on January 31, 1995.
- Following a special civil action for certiorari by the Office of the Solicitor General (OSG), the trial court was directed to impose the death penalty, which was done on May 22, 1996.
- The case was subject to automatic review due to the imposed death penalty.
Facts of the Case
- On August 2, 1994, at approximately 5:10 p.m., police discovered the body of Angel wrapped in a yellow tablecloth and placed inside a sack in a flooded street in Binondo, Manila.
- The victim’s body showed signs of severe trauma, including missing eyes, lacerated genitals, and multiple stab wounds.
- Angel had been reported missing by her family, who last saw her leaving to buy champorado on the evening of August 1, 1994.
- Witnesses, including store owners and neighbors, provided testimonies that placed Angel in the vicinity of where she was later found.
Investigation and Arrest
- The investigation revealed that Lagunday, an accused who later died, was the last known person seen with Angel.
- Witness Herminia Barlam, a laundry woman, provided crucial testimony claiming she witnessed the assault on Angel by Lagarto, Cordero, and Lagunday in a warehouse.
- Barlam identified Lagarto and Co