Case Summary (G.R. No. 232455)
Charges and Legal Basis
The accused were charged with "Robbery with Homicide with the Use of Unlicensed Firearm" under Article 294, paragraph 1 of the Revised Penal Code, as supplemented by Presidential Decree No. 1866. The information was filed on November 5, 1985, alleging that the accused conspired to rob Jacinto Salamanca and, in doing so, murdered him.
Procedural History
After the arrest of the accused on November 22, 1985, they were arraigned on December 4, 1985, entering pleas of not guilty. Accused Ricardo Adduca briefly posted bail and escaped custody before being re-arrested. Antonio Soriano also evaded arrest through unclear circumstances. Ultimately, the trial proceeded against Pugal, Adduca, and Soriano, while Artemio Panagan was dismissed from the case based on the victim's spouse's affidavit of desistance.
Trial Court's Findings and Judgment
The trial court issued a judgment on July 17, 1989, finding the three accused guilty beyond reasonable doubt of the crime charged, sentencing each to reclusion perpetua and ordering them to indemnify the victim's heirs. The decision found that the crime was committed with aggravating circumstances including treachery and nocturnity.
Appeal and Allegations of Error
Prudencio Pugal appealed the conviction, raising several errors regarding the testimonies' credibility of prosecution witnesses Hizon and Erlinda Salamanca, the admission of evidence, and the trial court's assessment of his alibi. Specifically, Pugal contended that the witnesses’ accounts were inconsistent and biased due to their relationship to the victim.
Examination of Witness Testimonies
The prosecution relied on the testimonies of the victim's family members, who stated they had positively identified Pugal and his co-accused as the perpetrators. Their accounts described the night of the crime, including how Pugal called out to Jacinto Salamanca before forcibly entering the home and subsequently committing theft and murder.
Defense's Alibi and its Weakness
Pugal’s alibi was presented as he claimed to have been at home during the incident. However, the prosecution’s witnesses provided a compelling identification supported by the circumstances surrounding the crime. The court reiterated that alibi is a weak defense, especially when contradicted by positive identification from witnesses.
Assessment of Witness Credibility
The court addressed the possible biases of the prosecution witnesses due to their familial relation with the victim. However, it upheld their testimonies, emphasizing that familial ties do not automatic
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Case Overview
- The case involves the crime of "Robbery with Homicide with the Use of Unlicensed Firearm" charged against Prudencio Pugal, Antonio Soriano, Ricardo Adduca, and Artemio Panagan.
- The incident occurred on July 23, 1985, in Riverside, Laya West, Tabuk, Kalinga-Apayao.
- The prosecution alleges that the accused, acting in concert, committed robbery and subsequently murdered Jacinto Salamanca.
Charges and Arrest
- An information was filed on November 5, 1985, leading to the arrest of the accused on November 22, 1985.
- All accused were initially arraigned and pleaded not guilty.
- Ricardo Adduca was released on bail but later escaped custody; Antonio Soriano was received by an acting mayor without proper court authorization and also remained at large.
- The case against Artemio Panagan was dismissed based on the victim's wife’s affidavit of desistance.
Trial and Judgment
- On July 17, 1989, the trial court convicted Pugal, Soriano, and Adduca, sentencing them to Reclusion Perpetua and ordering them to pay damages.
- Pugal appealed the decision, raising several errors alleged by the trial court.