Case Summary (G.R. No. 104497)
Charges and Proceedings
The appellants were charged with "Robbery with Homicide" through an Information filed on November 24, 1987. During their arraignment on February 11, 1988, the appellants pleaded "not guilty." The trial proceeded despite Alex Ramos remaining at large, and no eyewitness testimony was available.
Prosecution Evidence
The prosecution's case was built on the testimonies of police officers and medical experts. Patrolman Dante Asegurado of the Rizal police received a report about a robbery-slaying at Aida Sison's residence around 11:30 P.M. Upon arrival, the police found both victims dead, and the house in disarray, indicating a violent struggle. Two of the accused, Angel and Marco, were apprehended shortly thereafter, with Angel holding a blood-stained weapon.
Victim Injuries and Cause of Death
The postmortem examinations by Dr. Leon Rondilla, Jr., revealed that Aida died from severe head trauma caused by a blunt object, while Avelina suffered multiple stab wounds and trauma from sharp objects. The varying injuries indicated the assault was perpetrated by multiple attackers.
Defense Testimonies
The defense presented a different narrative, claiming that the appellants had been lured to the area by Alex Ramos under the pretense of buying lanzones (a local fruit). They described the events leading up to the crime, including their lack of prior acquaintance with Aida and their subsequent panic upon hearing a woman's screams for help during the attack.
Confessions and Police Interrogation
The appellants later signed sworn statements without the assistance of counsel, which they argued were obtained under duress and maltreatment during police interrogation. Angel even suffered a gunshot wound during the process, which he contended was inflicted by the officers.
Conviction and Sentence
Ultimately, the Regional Trial Court found the appellants guilty of robbery with homicide and sentenced each to "reclusion perpetua" (life imprisonment). The court also ordered them to pay civil damages to the victims’ heirs, which include indemnity and funeral costs.
Appellants' Appeal and Evidence Evaluation
On appeal, the primary issue was whether the circumstantial evidence presented by the prosecution was sufficient. The court emphasized that circumstantial evidence could convict if multiple circumstances led inexorably to the accused's guilt. The totality of evidence was deemed sufficient to confirm the guilt beyond reasonable doubt.
Analysis of Aggravating Circumstances
The court considered several aggravating c
...continue readingCase Syllabus (G.R. No. 104497)
Case Citation
- G.R. No. 104497
- January 18, 1995
- 310 Phil. 186
Background of the Case
- Appellants Angel Fernandez, Marco Fernandez, and Rodolfo Tulagan, alongside Alex Ramos (who remains at large), were charged with Robbery with Homicide.
- The incident occurred on October 26, 1987, at the residence of Mrs. Aida Sison in Barangay West Poblacion, Rizal, Laguna.
- The complaint stated that the accused conspired to enter the victim's home with deadly weapons, resulting in the death of the victims and theft of valuables worth ₱200,000.00.
Charges and Arraignment
- The Information was filed on November 24, 1987.
- The accused pleaded NOT GUILTY during their arraignment on February 11, 1988.
- Only the three appellants faced trial as Alex Ramos was not apprehended.
Prosecution's Evidence
- Multiple testimonies were presented:
- Patrolman Dante Asegurado received a report about the crime shortly after it occurred.
- Upon arrival, the police found the victims, Aida Sison (72) and her maid, Avelina Hernandez, dead in a disordered house.
- Appellants Angel and Marco were found crawling away from the scene, with Angel holding a blood-stained dagger.
- Rodolfo was arrested the next day, also possessing a knife.
- Dr. Leon Rondilla, Jr. performed the autopsy, confirming Aida's death was due to blunt force trauma and Avelina suffered multiple stab wounds, indicating a