Case Summary (G.R. No. 183622)
Procedural History
This appeal arises from a decision rendered by the Regional Trial Court, Branch 171, Valenzuela, Metro Manila. The appellant was found guilty beyond reasonable doubt of robbery with multiple homicide and sentenced to reclusion perpetua on three counts. The court ordered him to pay the heirs of the deceased for funeral expenses and damages.
Summary of Allegations
The information filed against the appellant described acts of robbery committed with violence, including the use of a bladed instrument against the victims. It alleged that the accused had unlawfully taken several items belonging to Alejandro Rivera and inflicted fatal injuries on the victims, resulting in their deaths.
Prosecution Evidence
The prosecution presented several eyewitness accounts establishing the appellant's presence at the crime scene and his involvement in the killings. Key witnesses included Eulogio Sanchez, Rowena Fernandez-Rivera, and Orlando Silvestre, who testified about their experiences during the events of the evening. These testimonies illustrated the drinking session that escalated into violence, wherein the appellant brandished a knife and attacked the victims.
Appellant's Defense
The appellant claimed he was under the influence of alcohol and drugs during the incident and did not have a clear recollection of what transpired. He denied intending to commit robbery and contended that any theft was an afterthought following the violence. He also challenged the sufficiency of the prosecution's evidence, arguing that the testimonies should not be considered reliable, particularly regarding the possession of stolen items.
Errors Assigned by the Appellant
The appellant raised two main errors in his appeal:
- The trial court erred in finding him guilty beyond a reasonable doubt of robbery with multiple homicide.
- Even if found guilty, the court erroneously imposed the penalty of reclusion perpetua for each count.
Legal Findings on Robbery and Homicide
The court addressed the legal definition of robbery with homicide, clarifying that the designation as robbery with multiple homicide was inaccurate. It determined that for such a conviction, the original intent must be robbery, which was not sufficiently established. The evidence pointed to a lack of prior criminal intent to steal, indicating that the taking of property occurred as an afterthought to the homicides.
Sufficient Circumstantial Evidence
While there were no eyewitnesses to the actual killings, the court acknowledged that circumstantial evidence could support a conviction. It concluded that multiple witnesses corroborated the appellant's presence, actions, and the retrieval of stolen items from his possession. The court ruled that the appellant had not provided a satisfactory explanation for his possession of the property, leading to an inference of guilt.
Final Ruling and Modifications
The court modified the trial court's decision, convicting the appe
...continue readingCase Syllabus (G.R. No. 183622)
Case Background
- This case arises from an appeal filed by the accused, Lawrence Ponciano y Sabolan, against a decision rendered by the Regional Trial Court, Branch 171, Valenzuela, Metro Manila.
- The trial court found the accused guilty beyond reasonable doubt of robbery with multiple homicide and sentenced him to suffer the penalty of reclusion perpetua for three counts.
- The decision also mandated the accused to pay the legal heirs of the victims for funeral expenses and indemnities.
Charges Against the Accused
- The information filed against Ponciano states that on July 29, 1986, he committed robbery and homicide in Valenzuela, Metro Manila.
- The specifics of the robbery include taking a Sony Betamax, a transformer, a rewinder, and wristwatches belonging to the victims, which were valued in Saudi Rials.
- During the commission of the robbery, the accused stabbed and assaulted three individuals—Regina Villanueva, Ricardo Rivera, and Alicia Rivera—resulting in their deaths.
Prosecution Evidence
- The prosecution presented multiple witnesses who testified about the events leading to the crime:
- Eulogio Sanchez: Stated he was present at a drinking session at Ricardo Rivera's house and testified about seeing the accused with a knife after the victims were injured.
- Rowena Fernandez-Rivera: Witnessed the accused brandishing a knife and later observed the chaotic aftermath, including the misplacement of household items and the injuries sustained by the victims.
- Amelita Rivera: Affirmed the familial rel