Title
People vs. Leonor
Case
G.R. No. 125053
Decision Date
Mar 25, 1999
Christopher Leonor robbed and fatally stabbed Dr. Tarlengco in her clinic. Despite his claims of unintentional harm, the Supreme Court convicted him of robbery with homicide, sentencing him to reclusion perpetua.

Case Summary (G.R. No. 125053)

Plea and Undisputed Factual Core

At arraignment the accused pleaded not guilty. It is undisputed, and the accused admitted, that on 15 May 1995 he stabbed Dr. Tarlengco at her clinic; that stab wound ultimately caused her death. The dispute centers on the surrounding circumstances, in particular whether the killing occurred on the occasion of a robbery.

Prosecution Case and Eyewitness Account

Prosecution witnesses (including a building security guard Reynaldo Baquilod, Police Officer Luis F. Galeno, PO3 Mateo Interia, family members and medical witnesses) described the sequence: an assailant entered the dental clinic, inquired about extraction costs, left and returned shortly, demanded money while the dentist was preparing instruments, stabbed her, grabbed her watch and ran. Baquilod pursued, recovered a Titus watch and P900 from the accused, and, with Galeno, apprehended him. A bloodied fan knife (balisong) was observed at the clinic.

Medical and Forensic Evidence

Medical testimony and the medico-legal report (NBI Medico-legal Officer) established that the chest stab wound could have been caused by a single-bladed fan knife and was fatal. Dr. Tarlengco was taken to hospital, underwent emergency operation, later spoke to her father and others about the incident, and subsequently died. The family incurred specified hospital and funeral expenses documented at trial.

Defense Version and Testimony of the Accused

The accused testified he traveled from Calauag with a fan knife, sought dental treatment for toothache, negotiated price, was seated for extraction, reacted when the dentist purportedly changed the price, pushed away the dentist’s hand, and then “blacked out” and later realized the dentist had been stabbed. He denied taking the money and watch. He alleged physical abuse by policemen during arrest and that police took clothing and money; he contested admissions allegedly made to police/prosecution representatives.

Evidentiary and Credibility Considerations

The trial court’s credibility determinations favored prosecution witnesses, and the Supreme Court observed the general rule of deference to the trial court on credibility, intervening only if weighty overlooked facts exist. Given the admitted stabbing, the burden shifted to the accused to establish justifying or exempting circumstances; he failed to prove any such circumstances.

Proof of Robbery: Possession and Corroboration

The Court found robbery proved by (1) positive identification by Geraldine Tarlengco and Joseph Sumalbar that the recovered watch and money belonged to the victim; (2) corroborative testimony of Baquilod and Galeno that the watch and cash were taken from the accused during pursuit and apprehension; and (3) the legal presumption that unexplained possession of recently stolen property implicates the possessor as the taker. The intercalation of the stolen items in a police referral report was explained as an honest correction and did not negate the substance of the evidence.

Dying Declaration and Its Admissibility

The victim’s statements to her father and to Dr. Franco identifying the assailant and recounting that he posed as a patient, demanded money, stabbed her and took her watch were treated as a dying declaration. The Court applied the established requisites for admissibility: the declaration referred to cause/circumstances of death; was made with consciousness of impending death; was voluntary and free from coercion; was offered in a criminal case where death was the subject of inquiry; and the declarant was competent. The dying declaration corroborated both the robbery and the homicide occurring on that occasion.

Legal Characterization: Robbery with Homicide

Given the proved taking with violence or intimidation and the contemporaneous fatal assault, the elements of robbery with homicide under Article 294(1) of the Revised Penal Code were satisfied. The Court rejected the accused’s contention that only homicide was proven, concluding both robbery and homicide were established beyond reasonable doubt.

Mitigating Circumstances: Claims and Rejection

The accused asserted multiple mitigating circumstances: lack of intent to commit so grave a wrong, sufficient provocation, passion and obfuscation, voluntary surrender, and voluntary confession. The Court rejected each:

  • Use of a deadly weapon inflicting mortal wounds on vital organs negates mitigation for lack of intent to commit so grave a wrong.
  • The asserted provocation (a push and abusive words) was neither proportionate nor sufficient to mitigate a violent retaliatory killing.
  • “Passion and obfuscation” were not shown; the accused’s description of momentary blacking out did not demonstrate loss of reason and self-control required for mitigation.
  • He did not

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.

About Privacy Terms