Title
People vs. Taneo y Canada
Case
G.R. No. 87236
Decision Date
Feb 8, 1993
Accused convicted of robbery with homicide after maid's death; co-accused's testimony and res gestae upheld, alibi rejected, indemnity increased.

Case Summary (G.R. No. 87236)

Filing of the Information and Pleas

In the information, the accused were alleged to have entered Dr. Sia’s house with intent of gain and without her knowledge or consent, to have taken several specified items, and to have attacked the maid Linda/Landa Robert by hacking her with a bottle of beer grande and RC Cola, causing injuries that resulted in her instantaneous death. Only Victor Taneo and Roy Codilla were apprehended. Bebot Escoreal remained beyond the court’s reach, and an alias warrant returned unserved. On 9 February 1987, Roy Codilla, assisted by counsel, pleaded not guilty, while Victor Taneo voluntarily pleaded guilty. The RTC issued an order finding Taneo guilty and sentencing him to reclusion perpetua. Trial on the merits then proceeded against Roy Codilla.

Prosecution Evidence at Trial

Dr. Herminia Sia testified on her hiring of Codilla as a guard for her Banilad residence and described her concern about Codilla’s associates, including Bebot Escoreal. She narrated that after she received information from neighbors that intruders were apprehended and that the maid had been brought to a hospital, she went to the Mabolo Police Station, where she saw Victor Taneo and other persons associated with her household. She stated that she later learned from Jose Robert that Codilla had invited him for beer drinks and that upon his return, the maid was already injured.

Dr. Sia observed blood in her house and, critically, she testified that at the ground floor of Perpetual Succour Hospital, in the presence of Corazon Gonzales and a policeman named Lopez, the severely injured maid Landa managed to reveal that Roy Codilla was the one who struck her. Dr. Sia presented this statement as the identifying account of her assailant made shortly after the crime.

The prosecution also presented the testimony of Victor Taneo, who described his role as a jeepney dispatcher and explained how he met Codilla through Bebot Escoreal. Taneo claimed that Codilla planned to rob Dr. Sia’s house as revenge. Taneo stated that Codilla directed him to procure money for beer and that Codilla and the others carried out the plan: Codilla persuaded the houseboy Jose Robert outside, told his companions to wait, and later the group went inside the house after Codilla signaled. Taneo further testified that once inside, Codilla boxed the maid, and that they used bottles to strike her on the forehead, head, and mouth. Taneo said the group took cassette recorders and tapes, while the other participants gathered calculators. He then narrated that Codilla instructed them to separate outside with the loot and that he and Arnel Go were arrested while leaving the house. Taneo added that in jail he had been offered money by Codilla’s wife and described the circumstances under which Codilla sought to influence him.

Patrol officer Enrico Ministerio testified that in response to a phone call he and his companions went to Dr. Sia’s residence, where they took custody of Taneo and Arnel Go captured by civilians. The next day, he arrested Codilla at the Duty Free Shop in Lahug, Cebu City.

Lastly, Dr. Jaime Perez testified that he treated Landa Robert for multiple lacerations on the head and face caused by a blunt object and that approximately five hours later the patient died due to compression of vital brain centers. He issued a death certificate marked as an exhibit.

Defense Evidence at Trial

The defense presented Police Cpl. Jovito Roa, who testified about catching two persons digging a tunnel at the Bureau of Jail and Penology compound, where one was Victor Taneo, and Taneo’s alleged statement that Roy Codilla had nothing to do with the robbery-homicide. The defense also called witnesses Lolit Cabriana and Felicidad Pareno, and Roy Codilla testified in his own behalf.

Roy Codilla denied participation and asserted an alibi. He stated that he lived in Camputhaw and claimed that on 22 December 1986 he was not at Dr. Sia’s house during the time of the crime. He claimed he went to his aunt’s house at Camp Lapulapu in the morning and thereafter stayed with relatives and only met Taneo after his arrest at the police station. He explained that he had been employed as a guard by Dr. Sia in 1984 and that she terminated his services in May 1985. He maintained that he did not take any valuable items from Dr. Sia and that Dr. Sia instigated Taneo to implicate him due to a prior incident involving an attempt to throw a grenade at another person’s house. He denied having quarrels with the arresting officers.

Cabriana testified that Taneo told her in jail that he killed the maid using an empty beer bottle and that his companion was Bebot Escoreal; she further stated that Codilla answered her when she asked why he was in jail, claiming he was not at the house when the crime was committed. Pareno testified that she saw Codilla at past 4:00 P.M. in their residence viewing television and that she did not see him afterward.

Trial Court Findings and Conviction of Roy Codilla

After giving full faith and credit to the prosecution’s version, particularly the testimony of Dr. Sia and the account provided by Victor Taneo, the RTC concluded that the prosecution proved Roy Codilla’s guilt beyond reasonable doubt. The RTC rejected Codilla’s alibi because his residence in Camputhaw was described as less than an hour by jeepney from Dr. Sia’s Banilad residence, making it not physically impossible for him to be at the scene. It also relied on the positive identification by Taneo, found to be credible.

In its Decision dated 14 December 1988, the RTC found Roy Codilla guilty of robbery with homicide, imposed reclusion perpetua, ordered him to indemnify the heirs of the deceased Landa Robert jointly and severally with Victor Taneo in the amount of P30,000.00, and ordered payment of costs. The RTC modified Taneo’s earlier indemnification order only with respect to indemnity.

Grounds of Appeal

Roy Codilla seasonably appealed, initially filing a notice of appeal directed to the Court of Appeals, though due to the penalty the records should have been elevated to the Supreme Court. The records were transmitted and ultimately accepted by the Supreme Court on 20 September 1989. Codilla’s counsel de oficio, appointed after death of counsel de parte, raised these assignments of error:

First, the trial court allegedly erred in considering Landa’s statement to Dr. Sia as part of res gestae, with the appellant arguing that the statement could have been made four hours or more after the incident and thus permitted fabrication, and that it did not meet requirements for dying declaration. Appellant also asserted that the maid’s impaired consciousness made the statement doubtful, and he questioned the absence of testimony from Gonzales and Lopez.

Second, the trial court allegedly erred in giving weight to Victor Taneo’s testimony, which Codilla claimed was weak and not credible because of prior robbery cases and alleged motivation to testify for sale—asserting Codilla’s wife could raise only P400.00 of the promised P2,000.00.

Third, the trial court allegedly erred in declaring that Codilla’s identity was established. The appellant argued that the conviction relied only on Dr. Sia’s account of the maid’s identification and on Taneo’s alleged inadmissible testimony. He faulted the prosecution for not presenting Jose Robert, whom appellant claimed could have explained Codilla’s presence or absence and the asserted sequence of movements described by Taneo.

Issues for Resolution

The appeal required the Supreme Court to determine whether the RTC correctly admitted Landa’s identification of the assailant as part of res gestae, whether it correctly assessed the credibility of Victor Taneo and the prosecution witnesses, and whether the evidence was sufficient to establish Roy Codilla’s identity and participation beyond reasonable doubt, given the defense of alibi and the asserted non-presentation of Jose Robert.

Appellate Ruling: Affirmance of Conviction With Modified Indemnity

The Supreme Court found the appeal devoid of merit. It reaffirmed the controlling appellate principle that credibility determinations by the trial court generally must not be disturbed unless the record shows facts of substance and value were plainly overlooked. After a careful examination of the record, it held that the RTC’s reliance on the testimonies of Dr. Sia and Victor Taneo was supported by the evidence and the trial court’s observation of demeanor.

Legal Basis and Reasoning on the Res Gestae Statement

The Court rejected the first assigned error and held that the RTC correctly treated Landa’s statement to Dr. Sia as part of res gestae. It reasoned that Landa’s declaration that Roy Codilla struck her was made while she was still at the Perpetual Succour Hospital waiting for admission and that she had been rushed immediately after the incident and operated for four hours. Landa died five days later.

The Court reiterated the requisites for admission as res gestae: the principal act must be a startling occurrence; the statements must be made before the declarant had time to contrive or devise; and the statements must concern the occurrence and its immediately attending circumstances. It adopted the formulation in People vs. Ner that res gestae statements are those made under the influence of a startling event witnessed by the declarant before time for thought or fabrication, and without undue influence, and that the interval of time is not rigidly fixed in case law. The Court held that, on the facts, even if appellant claimed the lapse could be four hours or more, the statement was still sufficiently close in time to be “so nearly contemporaneous” with the occurrence and made under circumstances that excluded design or deliberation. It also reasoned that because Landa was hovering between life and death, she could hardly be expected to conjure a story imputing false responsibility to the appellant.

The Court further held that appellant’

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.