Case Summary (G.R. No. L-61356-57)
Summary of Charges
The accused were charged with the crime of "Robbery with Multiple Homicide and Serious Physical Injuries" under the Amended Information, which states that they forcibly entered the home of the Lingad family and, during the course of the robbery, committed fatal assaults on three minor children: Glenly Lingad, Enrique Lingad, and Irene Lingad, causing their deaths, while inflicting serious injuries on another child, Grace Paule.
Trial Court Decision
The Regional Trial Court of Guagua, Pampanga, found the three accused guilty beyond a reasonable doubt and sentenced them to reclusion perpetua. The court acknowledged the presence of various aggravating circumstances, including nighttime, dwelling, abuse of superior strength, and that there were multiple victims. Each accused was ordered to pay damages to the heirs of the deceased as well as moral damages, along with the restitution of the stolen cash.
Facts of the Case
On the evening before the incidents, Adelaida Lingad left her children and niece at home while attending a wake nearby. During her absence, the accused entered the house by force, demanding money from the children. The children, recognizing the accused, were terrified, ultimately leading to them being stabbed after they revealed the hiding place of the cash. Grace Paule survived to identify the perpetrators, while her siblings and cousin were fatally injured.
Defense Strategy
Accused-appellant Tala asserted an alibi, claiming he was not at the scene of the crime as he was delivering watermelons at the time. However, the trial court dismissed this defense, concluding that the alibi was not credible, particularly given the short distance between the events at Adelaida's house and his claimed location.
Testimonies and Witness Statements
The court relied heavily on the testimony of Grace Paule, the lone survivor who positively identified the accused in court. Her previous extrajudicial statement was challenged for its credibility, as it did not initially name all the accused; however, the court found her courtroom identification compelling and consistent. Additionally, the dying declarations of the deceased children, corroborated by their mother, were pivotal in establishing the identities of the attackers.
Legal Considerations
The court applied the doctrine of res gestae to admit certain statements made by the victims, arguing that they were spontaneous remarks made
...continue readingCase Syllabus (G.R. No. L-61356-57)
Case Overview
- This case revolves around the appeal of accused Carlito Tala alias "Boy" from a decision by the Regional Trial Court of Guagua, Pampanga, convicting him and co-accused for robbery with homicide.
- The trial court found that the evidence presented established the elements of robbery with homicide beyond reasonable doubt against all accused.
Background of the Case
- On January 24, 1984, accused-appellants Tala, Tolentino, Matawaran, and John Doe were charged with robbery with multiple homicide and serious physical injuries.
- The crime was committed on November 8, 1983, in Lubao, Pampanga, where the accused allegedly broke into the home of Adelaida Lingad, stole cash, and attacked her children.
Incident Details
- Adelaida Lingad left her children alone at home to attend a wake, leaving behind P4,000 in cash.
- The accused forcibly entered the house by breaking a wooden window grill and demanded the children disclose the location of the cash.
- During the robbery, the accused stabbed the children, resulting in the deaths of Glenly, Enrique, and Geraldine, while Grace Paule survived with serious injuries.
Trial Court Findings
- The trial court found that the prosecution proved actual damages of P90,000, including medical and funeral expenses, and assessed moral damages