Case Summary (G.R. No. 218628)
Incident Overview
On February 28, 1996, around 7:00 PM, Lydia Cuenca was driving her vehicle along Commonwealth Avenue, followed by her husband Manuel in another car. As Lydia attempted a U-turn, three armed assailants approached her vehicle, forcibly trying to gain entry. Despite their attempts, including gunfire that struck Lydia, the assailants managed to break a window and enter her vehicle, ultimately speeding off with Lydia inside. The incident lasted approximately five to ten minutes, during which Manuel attempted to pursue the assailants but failed. Support was sought from bystanders, and the police were alerted to the unfolding robbery.
Police Response and Initial Investigation
Upon receiving multiple reports about the robbery, a police team, including several officers, was dispatched to the scene. They found Lydia severely injured and proceeded to take her to the hospital, where she succumbed to her injuries. Various pieces of evidence were recovered, including firearms from the suspects and the victim's belongings. A confrontation with the suspects ensued at a nearby compound where a shootout occurred, leading to the apprehension of the accused-appellants.
Autopsy and Forensic Evidence
An autopsy was performed on Lydia Cuenca by Dr. Alvin David of the National Bureau of Investigation (NBI), revealing two fatal gunshot wounds. The forensic analysis indicated that the wounds were consistent with shots fired from a caliber .38 firearm. Ballistic examinations supported the findings, linking the bullets retrieved from the victim's body to the firearms possessed by the accused.
Criminal Charges Filed
Both Edgardo Liad and Jun Valderama were charged with robbery with homicide under Article 294 of the Revised Penal Code, along with illegal possession of firearms. The prosecution presented evidence, including testimony from Manuel Cuenca, witnesses, and police officers, to establish a chain of events leading to the robbery and the victim's death.
Defense and Testimonies
The accused-appellants denied their involvement in the crime. Valderama claimed he was selling goods at the time of the robbery and was wrongfully arrested by the police, alleging coercion and torture to extract a confession. Liad admitted to his presence at the crime scene but denied participating in the robbery. The defense aimed to disprove the prosecution's narrative by providing alternative explanations for their actions during the incident.
Trial Court Decision
The Regional Trial Court found the accused-appellants guilty of robbery with homicide and illegal possession of firearms. They were sentenced to reclusion perpetua and ordered to pay damages to the heirs of Lydia Cuenca. The court emphasized the presence of a conspiracy among the perpetrators and highlighted the positive identifications made by Manuel Cuenca as credible.
Appeal and Judicial Review
On appeal, the accused-appellants contested their identification as co-conspirators and challenged the validity of the illegal possession of firearm charges. The Supreme Court affirmed the conviction for robbery with homicide, concluding that the prosecution met the burden of proof regarding conspiracy and participation in the cr
...continue readingCase Syllabus (G.R. No. 218628)
Case Overview
- This case involves a robbery with homicide that occurred on the night of February 28, 1996, in Quezon City, Philippines.
- The victim, Lydia Cuenca, was attacked while driving her vehicle, resulting in her death and the theft of her belongings.
- The accused-appellants, Edgardo Liad and Jun Valderama, were charged with robbery with homicide and illegal possession of firearms.
Incident Description
- Lydia Cuenca was driving her Tamaraw FX along Commonwealth Avenue, with her husband Manuel following in another vehicle.
- As Lydia attempted to make a U-turn, three men approached her car, attempted to force it open, and shot at her when they were unsuccessful.
- Lydia sustained gunshot wounds, and the attackers ultimately took her vehicle and fled the scene.
- The entire incident lasted approximately five to ten minutes, during which Manuel Cuenca tried to intervene and pursue the attackers.
Police Response and Apprehension of Suspects
- After the incident, police were alerted and dispatched to the scene.
- The suspects were located in a nearby compound, where a shootout ensued between the police and the suspects.
- Two of the suspects, Liad and Valderama, surrendered to the police and were apprehended with firearms linked to the incident.
- Lydia Cuenca was taken to the hospital but was pronounced dead upon arrival.
Autopsy and Ballistics Evidence
- An autopsy conducted by Dr. Alvin David confirmed that Lydia died from multiple gunshot wounds, with evidence indicating close-range firing.
- A ballistic examination of