Case Summary (G.R. No. 144621)
Relevant Legislation
The applicable law in this case is the 1987 Philippine Constitution and the corresponding Penal Code provisions regarding robbery and homicide, particularly the elements that constitute conspiracy and the evidentiary standards required for conviction.
Facts of the Case
On September 1, 1992, an amended information was filed, charging the accused with robbery with double homicide occurring on July 17, 1992. The victims, the Jael spouses, were attacked and killed by the accused, who stole several personal items valued at P67,800. Masinag denied any involvement in the crime, claiming she had no motive nor did she collude with any of the other accused.
Trial Court's Findings
The trial court found Masinag and Osabel guilty beyond a reasonable doubt of robbery with homicide, sentencing them both to reclusion perpetua, along with ordering them to indemnify the heirs of the victims. The trial court's decision relied heavily on the testimonies of state witness Ariel Dador, who detailed a plan to rob the victims and implicated Masinag and Osabel's involvement in that plan.
Appellant's Arguments
Masinag, in her appeal, argued that the trial court erred in finding her guilty based on insufficient evidence, particularly contesting the reliability of the extrajudicial confessions made by Osabel and Dador. She maintained that both witnesses lacked personal knowledge regarding her participation and that their testimonies were primarily hearsay, hence inadmissible as evidence against her.
Evaluation of Evidence
The court emphasized the principle that hearsay evidence is inadmissible, which applies to Dador's account as he lacked direct communication with Masinag regarding the conspiracy. Furthermore, Osabel’s extrajudicial confession was deemed inadmissible against Masinag due to the res inter alios acta rule, meaning that Osabel's admissions could not prejudice Masinag, who was not invol
...continue readingCase Syllabus (G.R. No. 144621)
Overview of the Case
- The case involves the appeal of Decena Masinag Vda. de Ramos against the decision of the Regional Trial Court of Lucena City, Branch 60.
- The trial court found her and Cesar Osabel guilty of Robbery with Homicide, sentencing them to reclusion perpetua and ordering them to pay indemnities to the heirs of the victims.
- The case was decided on May 9, 2003, under G.R. No. 144621.
Background of the Case
- An Amended Information was filed on September 1, 1992, against several accused, including Masinag and Osabel, for the crime of Robbery with Double Homicide.
- The incident took place on July 17, 1992, in Lucena City, where the accused allegedly conspired and committed robbery, resulting in the fatal stabbing of spouses Romualdo Jael and Lionela Caringal.
Allegations and Charges
- The accused were alleged to have stolen various valuable items worth a total of P67,800.00, and executed the crime using bladed weapons.
- The specifics of the robbery included the theft of gold and diamond jewelry, cash, and other personal belongings from the victims.
- The prosecution argued that the accused acted with intent to kill to prevent the victims from reporting the robbery.
Trial Proceedings
- During the trial, Ariel Dador, a state witness, testified about the planning and execution of the robbery.
- Dador claimed that he was informed by Osabel about the plan to rob the Jael spouses.
- Evidence included extrajudicial confessions