Case Summary (G.R. No. 228000)
Events Leading to the Charge
The Information filed on November 26, 2007, alleged that at around 11:05 PM, the accused, acting in concert with Lester Ladra y Palema, Edwin Manzanero y Bautista, and Marvin Marqueses, attempted to steal a cell phone from Enicasio by using violence and intimidation. During the commission of the robbery, Enicasio was stabbed and later died as a result of the injuries sustained.
Arraignment and Charges
Upon arraignment, Ladra, Saldua, Palema, Palmea, and Grengia pleaded not guilty, while Marqueses remained at large. Post-arraignment, the prosecution presented evidence that included testimonies of witnesses present during the crime, notably the family of the victim and an eyewitness.
Testimonies and Evidence Presented
Eyewitness accounts detailed that the accused approached Enicasio, leading to a physical confrontation wherein Palema stabbed the victim. Despite attempts by Enicasio's family to intervene and help him, he succumbed to his injuries after being taken to a medical facility. Testimony from the family revealed incurred expenses amounting to medical bills and funeral costs.
Defense Strategy
The accused-appellants maintained their innocence, denying any participation in the crime. They argued that they were at the plaza but not as a group and contested the credibility of the witnesses. Notably, Ladra later changed his plea to guilty, providing a clearer account of the events leading to the attack on Enicasio.
Regional Trial Court's Decision
On April 15, 2013, the Regional Trial Court found Palema, Palmea, Saldua, and Grengia guilty of robbery with homicide, sentencing them to reclusion perpetua. The court held that the actions of the accused demonstrated conspiracy to commit the crime, affirming that the intent to rob existed and that the homicide arose directly from this intent. They were also ordered to pay damages to Enicasio's heirs.
Appeal to the Court of Appeals
The accused appealed the Regional Trial Court's decision, arguing flaws in the witness testimonies, particularly discrepancies regarding the location of the stab wound and the existence of conspiracy. The Court of Appeals, however, upheld the Trial Court’s ruling, emphasizing the credibility of the witnesses and the circumstantial evidence that confirmed the existence of conspiracy among the accused.
Supreme Court's Ruling
Upon review, the Supreme Court affirmed the Court of Appeals' ruling and the Regional Trial Court's decision. The Court discussed the nature of robbery with homicide as defined under Article 294 of the Revised Penal Code, affirming that the original intent of the perpetrators must be to commit robbery, with
...continue readingCase Syllabus (G.R. No. 228000)
Overview of the Case
- This case involves the prosecution of Ronald Palema y Vargas, Rufel Palmea y Bautista, Lyndon Saldua y Quezon, and Virgo Grengia for the crime of robbery with homicide.
- The case originated from an incident that occurred on November 10, 2007, at the Calamba Town Plaza, where Enicasio Depante y Rosales was attacked and ultimately killed during a robbery.
- The initial decision of the Regional Trial Court (RTC) on April 15, 2013, convicted the accused of robbery with homicide, which was later affirmed by the Court of Appeals (CA) on May 18, 2016.
Elements of Robbery with Homicide
- The prosecution must prove the following elements beyond a reasonable doubt:
- The taking of personal property through violence or intimidation against persons.
- The property taken must belong to another.
- The taking was done with intent to gain (animo lucrandi).
- Homicide must be committed on the occasion of the robbery.
Factual Background of the Incident
- Around 11:00 p.m. on November 10, 2007, Enicasio Depante, along with his family, was seated at the plaza when the accused approached him.
- The attack commenced when Palmea attempted to punch Enicasio to grab his phone, with Palema pulling out a knife and stabbing him.
- Grengia and Saldua joined the assault, leading to Enicasio’s eventual collapse from stab wounds.
- Despite attempts to assist him, Enicasio succumbed to his injuries later at the hospital.
Evidence Presented
- Testimonies from Enicasio's family indicated they incurred significant medical and funeral expen