Case Summary (G.R. No. 183053)
Procedural Background
This summary follows an appeal filed by Charito Fernandez under Section 13, Rule 124 of the Rules of Court against the Decision of the Court of Appeals that upheld the ruling of the Regional Trial Court (RTC) convicting Charito of Robbery with Homicide, arising from events occurring on August 8, 2004.
Facts of the Case
On two occasions in July and August 2004, Charito and co-accused Rogelio Lasconia conspired to rob the Valleceras. The plan was to have Dionesia Lasconia, a house help, facilitate access to the victims' home. The initial attempts to rob the house were unsuccessful due to absences and superstitious beliefs. However, on August 8, 2004, the group executed their plan. Dionesia opened the back gate for the masked intruders, Rogelio Lasconia, Eddie Fernandez, and Rommel Escobio. The three quickly subdued the victims and stole valuables, ultimately leading to the murder of Erlinda.
Charges and Legal Proceedings
An Information was lodged against Charito and several others for Robbery with Homicide. Throughout the trial, various plea deals were made, with Dionesia allowed to plead guilty to a lesser charge, while evidence presented by state witness Joseph Oronos established Charito's direct involvement in the planning and execution of the crime.
Ruling of the RTC
The RTC convicted Charito and sentenced him to reclusion perpetua, imposing liability for funeral expenses and damages. Charito's appeal followed, claiming insufficient evidence regarding his participation.
Ruling of the Court of Appeals
The Court of Appeals affirmed the RTC’s ruling against Charito, noting that he actively participated in planning, assisting with the robbery, and even threatened their getaway driver. However, the CA acquitted co-accused Eddie Olazo and Miguel Corbis for lack of evidence.
Issues for Resolution
The primary issue presented was whether the RTC erred in convicting Charito based on the available evidence. Charito asserted that the prosecution failed to demonstrate his guilt beyond a reasonable doubt.
Court's Ruling
The Supreme Court reaffirmed the lower courts’ decisions, emphasizing the trial court's unique position in assessing witness credibility. Charito’s involvement was substantiated by direct testimonies and circumstantial evidence which demonstrated conspiracy and conscious participation in the crime.
Legal Principles Applied
The Court highlighted the definition of conspiracy, noting its presence was evidenced not strictly by direct acts but through the collective behaviors of the accused. The testimonies from state witn
...continue readingCase Syllabus (G.R. No. 183053)
Case Background
- This case is an appeal filed under Section 13, Rule 124 of the Rules of Court from the Decision dated June 2, 2015, of the Court of Appeals (CA), affirming the Decision dated June 14, 2011, of the Regional Trial Court (RTC) of Abuyog, Leyte, in Criminal Case No. 2402.
- The accused-appellant, Charito Fernandez, was found guilty of Robbery with Homicide.
Incident Overview
- The crime took place on August 8, 2004, in Barangay Bito, Abuyog, Leyte, where the accused conspired to rob spouses Erlinda and Nicanor Vallecera.
- Dionesia Lasconia, a stay-out house help for the Vallecera couple, played a key role in allowing the intruders access to the house.
Planning Stages
- Meetings to plan the robbery were held in July and August 2004, involving multiple accused persons. However, prior attempts to execute the plan were thwarted.
- On the day of the crime, Dionesia returned to the Vallecera home, left a back gate open for her co-accused, and prepared for the arrival of the intruders.
Execution of the Crime
- Around 7 PM, Rogelio Lasconia, Rommel Escobio, and Eddie Fernandez, all wearing masks, entered the Vallecera home.
- They confronted Erlinda Vallecera, threatened her with a gun, and hogtied Nicanor Vallecera.
- The intruders forced Erlinda to open a vault, stealing cash and jewelry.
- Following the robbery, Erlinda was brutally attacked and killed by Rommel Escobio and Rogelio Lasconia.
Legal Proceedings
- An Information was filed against the accused on February 21, 2005, charging them with Robbery with Homicide.
- During the arraignment, Rommel Escobio pleaded guilty, while Eddie Fernan