Case Summary (G.R. No. 94471)
Background of the Incident
The accused-appellants were implicated in a robbery that escalated to an attempted homicide. During the incident, Alejo and Lourdes Flavier, along with relatives, were watching television in their house. Four individuals armed with knives and firearms entered under the pretext of purchasing cigarettes, but soon after, they demanded money and valuables. Alejo Flavier was subsequently stabbed by one of the intruders, identified later as Nelson Ledesma.
Trial Court Proceedings
The Regional Trial Court, presided over by Judge Enrico A. Lanzanas, found all accused-appellants guilty of robbery with frustrated homicide, sentencing them to reclusion perpetua. They were also ordered to jointly reimburse the Flaviers for the stolen properties and medical expenses incurred due to Alejo Flavier's injuries. Importantly, one accused, Elmer Paglinawan, escaped confinement but was killed during the proceedings, leading to the dismissal of the case against him.
Evidence and Testimonies
The prosecution presented multiple eyewitnesses who positively identified the accused-appellants as the perpetrators. The court noted that these identifications occurred in a well-lit environment, minimizing the likelihood of mistaken identity. Despite the defendants’ invocation of denial and alibi as their defenses, the trial court found the testimonies credible and consistent, particularly noting the affirmative evidence presented by the prosecution.
Accused-Appellants' Defense
The defense argued that the testimonies from the prosecution's witnesses contained inconsistencies and were based on coerced confessions taken without legal assistance. However, the trial court did not consider these confessions as basis for the verdict, relying instead on eyewitness accounts to affirm the accused's guilt.
Legal Findings
The appeal brought forth by the accused-appellants asserted that the prosecution failed to prove their guilt beyond a reasonable doubt and that inconsistencies in witness statements justified their acquittal. However, the appellate court reiterated that an alibi is a weak defense against positive identification and that circumstantial evidence and corroboration from eyewitness accounts sufficiently supported the verdict.
Conclu
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Case Overview
- The case involves the appeal of accused-appellants from the decision of the Regional Trial Court sentencing them to reclusion perpetua for robbery with frustrated homicide.
- The trial court ordered the accused to reimburse the offended party a total of P10,195.00 for stolen properties and P8,000.00 for medical expenses incurred by the victim, Alejo Flavier.
- During the proceedings, one of the accused, Elmer Paglinawan, escaped from confinement and was later killed, leading to the dismissal of the case against him.
Facts of the Case
- On the evening of September 30, 1987, the Flavier family was at home in Barangay Tan-ag, Lopez, Quezon, watching television when they were approached by individuals claiming to be members of the New People’s Army.
- Upon requesting to see Alejo Flavier, the intruders followed him into the house while armed with weapons.
- The armed men demanded money and valuables from the family and threatened them, leading to Alejo being stabbed by Nelson Ledesma.
- Alejo Flavier suffered serious injuries but survived due to timely medical intervention, while the robbers managed to escape with significant loot.
Prosecution Evidence
- The prosecution relied on the testimonies of Alejo Flavier, Lourdes Flavier, and their daughter-in-law, Regulita Flavier, who identified the accused as the perpetrators of the crime.
- The evidence indicated that the robbery was carried out by a group of at least six individuals who conspired and acted in concert.
- The trial court pla