Case Summary (G.R. No. 108733)
Background of the Incident
On March 4, 1992, the day of the incident, Leticia Perez had called her son Michael for assistance at the restaurant since other family members were unavailable. Michael assisted his mother and noted that there were considerable amounts of money in the cash register, which he placed in his mother's bag before leaving the premises. After Michael left, Leticia ascended to her bedroom with her bag, and subsequently, she was found dead by Michael upon his return that evening.
Events Leading to the Crime
During the time leading up to Leticia's death, several witnesses, including employees of the restaurant, observed the activities around the establishment. At approximately 3:00 PM, Renante was seen engaging with other employees and later supposedly left the immediate area around 4:45 PM, prior to the discovery of the victim's body. When Michael returned around 8:00 PM, he found Leticia unresponsive and subsequently, an investigation was initiated.
Discovery and Forensic Findings
The autopsy performed by Dr. Marcial Cenido determined that the cause of death was asphyxia by strangulation. This finding reinforced the suspicions of foul play, ultimately leading to the investigation focusing on Renante after reports surfaced regarding his alleged confession of strangling Leticia and robbing her of money.
Investigation and Arrest
On March 6, 1992, Renante was detained and allegedly confessed to the crime during questioning. However, significant legal issues arose regarding the admissibility of this confession due to the lack of proper advisement of his constitutional rights during such custodial interrogation. As stipulated by Section 12, paragraph 1 of Article III of the 1987 Philippine Constitution, all individuals under custodial investigation must be informed of their right to remain silent and to have legal counsel. The prosecution bore the burden of proving that Renante's confession was validly obtained, which it ultimately failed to do.
Legal Basis for Appeal
Renante's defense primarily relied on alibi and the contention that the circumstantial evidence presented by the prosecution did not meet the threshold of proving guilt beyond a reasonable doubt. The court emphasized that to support a conviction for robbery with homicide, there must be conclusive evidence proving both the act of robbery and the act of homicide. The absence of eyewitness accounts and the failure to recover stolen property weakened the prosecution's case significantly.
Findings on Circumstantial Evidence
The court evaluated the circumstant
...continue readingCase Syllabus (G.R. No. 108733)
Case Overview
- The case centers on the conviction of Renante Parel y Tejamo for the special complex crime of robbery with homicide.
- The Regional Trial Court of Manila sentenced him to reclusion perpetua and ordered him to indemnify the heirs of the victim, Leticia Perez, with P50,000.00 for her death and P70,412.00 for actual damages.
- The prosecution's argument relied heavily on circumstantial evidence.
Background of the Case
- Leticia Perez ran a restaurant named Le Mars Food House at No. 871 G. Apacible Street, Ermita, Manila.
- The restaurant employed twenty-eight workers, including the accused’s common-law wife, Estrellita San Luis, who was also Leticia's half-sister.
- On March 4, 1992, Leticia was found dead in her bedroom following a series of events involving various employees and family members.
Timeline of Events
- On the day of the incident, Leticia called her son Michael, who came to help at the restaurant while his mother was alone.
- Michael noted there was P6,000.00 in the cash register before leaving the restaurant around 2:00 PM.
- At approximately 3:00 PM, Renante was seen in the restaurant, involved with other employees.
- By 4:30 PM, Renante was last seen by Jean Santollo, who noted his unusual absence during a phone call.
- L