Case Summary (G.R. No. 169576)
Factual Background
On August 27, 1993, at approximately 2:00 A.M., Rodelo Palijon, Carlos Decena, and Jim Mercene conspired to rob the residence of elderly spouses Gonzalo and Mellorequina Reyes in San Pablo City. The plan involved subterfuge and violence; Decena gained entry by forcibly removing glass panes from the jalousy windows. Once inside, he and Mercene awaited Mrs. Reyes, who unknowingly confronted them while going to the bathroom. Decena physically assaulted her, rendering her unconscious, and subsequently attacked Mr. Reyes with a steel stool, leading to his death from injuries sustained during the assault. The robbers fled with cash and jewelry valued at P117,000.
Charges and Initial Proceedings
An Information was filed against the accused, including Palijon, Pria, Decena, and Mercene, for robbery with homicide in violation of the Revised Penal Code. The accused were arraigned on November 9, 1993, each pleading not guilty. During trial, Decena and Mercene changed their plea to guilty for the lesser charge of homicide; they were subsequently sentenced to imprisonment with restitution to the victim's heirs.
Trial and Evidence Presented
The prosecution's case focused significantly on the testimony of Jim Mercene, who identified Palijon and Pria as co-conspirators, asserting that the robbery was premeditated and executed by the group, including Pria's knowledge of the victims' wealth as balikbayans. The trial court evaluated witness testimony and physical evidence, including stolen property recovered post-crime, which linked the accused to the act.
Defenses Raised
Palijon asserted a defense of denial and alibi, claiming to have been in Pila, Laguna during the incident. He argued police misconduct occurred during his arrest. Pria denied participating in any planning, stating she was unaware of the robbery until the aftermath was underway, and highlighted her familial connection to the victims as mitigating factors.
Due Process and Preliminary Investigation Claims
Pria claimed her right to due process was violated due to the lack of a preliminary investigation prior to her arraignment. However, the court upheld that she had waived this right by participating actively in the trial following her arraignment without contesting the procedural aspects of her arrest.
Legal Findings on Conspiracy and Guilt
The appellate court examined the conspiracy argument and established that acts of individual conspirators could collectively implicate all members. It reiterated the importance of proving robbery elements, including asportation and intention to gain. The court evaluated tes
...continue readingCase Syllabus (G.R. No. 169576)
Case Background
- The case arises from a judgment rendered by the Regional Trial Court of San Pablo City, Branch 32, on August 25, 1995.
- The appellants, Rodelo Palijon y Urhina (also known as "Madel") and Myra Pria y Bagsic, were found guilty beyond reasonable doubt of Robbery with Homicide.
- The trial court imposed the penalty of reclusion perpetua on both appellants.
Facts of the Case
- On August 27, 1993, at around 2:00 A.M., Rodelo Palijon, Carlos Decena, and Jim Mercene entered the Reyes couple's residence in San Pablo City.
- Decena unlawfully accessed the house by removing glass panes from jalousy windows.
- The robbers intended to steal cash and jewelry, while Palijon acted as a lookout outside.
- At approximately 4:00 A.M., Mrs. Reyes exited her bedroom and was assaulted by Decena, who then attacked Mr. Reyes when he rushed to help her.
- The couple was severely beaten, resulting in Mr. Reyes’s eventual death due to injuries sustained during the assault.
- Prosecution witness Merly Reyes Alvero discovered that P17,000.00 in cash and jewelry worth P100,000.00 were missing from the Reyes residence.
- Mr. Reyes died at the hospital later that morning, with the cause of death linked to severe head injuries.
Charges and Arraignment
- An Information was filed on October 14, 1993, charging the accused with robbery and homicide for the events of August 27, 1993.
- The accused were arraigned on November 9, 1993, where they pleaded "Not Guilty."
- Decena and Mercene later withdrew their plea and pleaded "Guilty" to the lesser offense of homicide, receiving a lighter