Case Summary (G.R. No. 89376)
Incident Overview
On the evening of the crime, Edison Paras was at his furniture store, returning items for closing. After letting in the accused, who were acquaintances, a commotion ensued, leading to Paras being stabbed multiple times. Witnesses, particularly an employee named Romeo Rotone, observed the stabbing through a glass divider between the store and the sala where the attack occurred. Paras managed to call for help, indicating he was attacked by both Lorenzo and Gonzales before succumbing to his injuries.
Victim's Death and Medical Findings
Edison Paras suffered 26 stab wounds, with 24 deemed fatal, resulting in severe hemorrhage. Dr. Maximo Reyes conducted the autopsy and confirmed that the victim had defensive wounds, indicating a struggle. The gruesome nature of the injuries underscored the violence of the attack, discrediting claims from the defense that another individual was responsible for the stabbing.
Defense Arguments
The accused presented an alternative narrative, claiming that they were at the victim's house for a birthday celebration and that another individual, referred to as "Gary Kabayo," was the one who fatally assaulted Paras. However, they failed to substantiate their version of events with credible evidence or witnesses.
Trial Court's Findings
The Regional Trial Court found both Lorenzo and Gonzales guilty of robbery with homicide, sentencing them to reclusion perpetua and ordering indemnities to the victim's family. The court relied on the eyewitness testimony of Rotone, along with medical findings, to establish the presence of conspiracy between the co-accused, which is critical in cases of joint criminal activity.
Appellate Review and Legal Standards
The appeal centered on the assessment of witness credibility, the sufficiency of evidence regarding conspiracy, and the constitutional rights of Gonzales during police interrogation. The appellate court reaffirmed the trial court's factual findings, emphasizing that establishing conspiracy does not require proof that each accused participated in every detail of the crime.
Evidence of Robbery Component
While the prosecution was unable to recover the full assets allegedly stolen, a sum of P1,711.00 was found in Gonzales’s possession shortly after the incident. This was deemed sufficient to affirm robbery as part of the compound offense of robbery with homicide, despite th
...continue readingCase Syllabus (G.R. No. 89376)
Case Overview
- The case involves the accused-appellants Dionisio Lorenzo y de Ocampo and Jeg Gonzales y Bulahabo, charged with robbery with homicide.
- The incident occurred on March 31, 1989, in Caloocan City, where the victim Edison Paras was killed during the commission of the robbery.
- The prosecution’s information alleges that the accused acted in conspiracy with intent to rob and kill Edison Paras, resulting in his death from multiple stab wounds.
Procedural History
- An information for robbery with homicide was filed against the accused on April 3, 1989, in the Regional Trial Court, Branch 131, Kalookan City.
- The trial court found both accused guilty and sentenced them to reclusion perpetua, imposing indemnity to the victim's heirs.
Factual Background
Victim's Circumstances:
- Edison Paras was in his furniture store on the evening of March 31, 1989, preparing to close for the day.
- Witnesses included employees Romeo Rotone and Aling Ukit, the former staying behind to help the victim celebrate his birthday the next day.
Events Leading to the Crime:
- The accused entered the store after the victim opened the door, supposedly to watch a film.
- A commotion was heard by Rotone, leading him to witness the stabbing through a glass divider.
- Rotone observed Gonzales and Lorenzo stabbing Paras with a knife while he was mortally wounded.
Aftermath of the Incident:
- Edison Paras managed to call for help before collapsing, ultimately succumbing to his injuries diagnosed as severe hemorrhage caused by multiple stab wounds.
- Neighbors and police arrived shortly after, leading to t