SABADO,SINTA V.

BAPS 3B

People vs. Villaflores

G.R. No. 184926, April 11, 2012

FACTS: Edmundo Villaflores, also known as “Batman”, was accused of raping a four-year-old
girl named Marita. On July 2, 1999, Marita was last seen by her mother Julia to be playing at the
near of their home, when her mother noticed that she was missing, she called her husband who
rushed home to find their daughter. At 6:00AM of July 3, 1999, they found Marita’s lifeless body
covered with a blue and yellow sack inside the comfort room of an abandoned house about five
structures away from their own house. Her face was black and blue, and bloody. She had been
tortured and strangled till death. The result of the post mortem examination showed that the child
was raped and the cause of death is asphyxia by strangulation.
Two witnesses, Aldrin Bautista and Jovy Solidium, pointed Villaflores as the culprit. They saw
Villaflores leading Marita by the hand, and later heard cries of a child. At about 7:00PM both
witnesses saw Batman carrying a yellow sack which appears heavy, the same sack that he saw
when they are still inside the house of Batman. The wife of the accused also gave a supporting
testimony that on the night of July 2, 1999 she saw his husband place some sacks under their
house and then went closer and saw a protruding elbow inside the sack, when she confronted his
husband who was on drugs, Villaflores said it was nothing. Based from these circumstances, the
RTC convicted Villaflores of a rape with homicide holding that the circumstantial evidence led to
no other conclusion but that his guilt was shown beyond reasonable doubt. The accused appealed
and argued that both RTC and CA erred in convicting him of a composite crime of Rape with
homicide through circumstantial evidence.
ISSUE: Can the accused be convicted of a composite crime of rape with homicide through
circumstantial evidence?
RULING: YES. Thus, in order to convict Villaflores of the composite crime of rape with
homicide, the State needs demonstrate that the following facts which are: (a) that Villaflores had
carnal knowledge of Marita; (b) that he consummated the carnal knowledge without the consent
of Marita; and (c) that he killed Marita by reason of the rape.
If the accused has carnal knowledge of a female under the age of 12, rape is always considered to
have occurred, according to the RPC as amended. A female of that age is regarded incapable of
consenting to the carnal knowledge, which is why the offense is also known as "statutory rape."
Marita’s Certificate of Live Birth Disclosed that she was born October 29, 1994.
making it clear that she was only four years and eight months old when the crime was committed
on July 2, 1999. Hence, Villaflores's carnal knowledge would amount to statutory rape. When a
killing takes place on the same occasion as a rape, which includes when it happens before, after,
or even during the attempted or completed rape, the crime is classified as a composite crime of
rape with homicide for as long as the killing is connected to the rape. Although the testimony of
the victim herself is the best evidence to prove rape, the court's rules allow circumstantial
evidence to prove the crime was committed and to identify the offender when the rape victim is
killed, so long as the circumstantial evidence is sufficient to support a conviction.
 Josue R. Ladiana Vs. People of the Philippines
G.R. No. 174660, May 30, 2011

FACTS: On December 1989, petitioner, a public official who was then serving as an INP
member assigned to the Lumban Police Station in Lumban, Laguna, encountered Francisco San
Juan as the latter was removing the steel pipes that had been used as a barricade to stop vehicles
from entering along P. Jacinto Street, Barangay Salac, Lumban, Laguna. When Francisco San
Juan told the accused that the latter had no authority to stopping him, the accused, who was
armed with a firearm, deliberately attacked and shot San Juan with the intention to kill, thereby
causing the death of Francisco San Juan.

ISSUE: Whether or not, the counter-affidavit of the accused, who was not assisted by counsel at
the time, can be admitted as evidence of guilt beyond reasonable doubt.

RULING: Yes. The purpose of a preliminary investigation is to ascertain whether there is

sufficient evidence to support a well-founded suspicion that a crime has been committed and that
the respondent should be detained pending trial. Evidently, a person who is the subject of a
preliminary inquiry by the public prosecutor cannot be regarded as being under investigation in a
detention facility. In fact, this Court has categorically stated that a defendant who is in court or
under preliminary investigation is not under custodial interrogation.
There is no doubt that the concessions made by the petitioner in his Counter-Affidavit, even in
the absence of counsel, do not violate his fundamental rights. It is obvious from the uncontested
facts that it was not demanded by the police when he was being held or questioned. Therefore, in
this case, the constitutional rights of a person who is the subject of a custodial investigation as
stated in Article III, Section 12 of the 1987 Constitution, are not in issue.
 People Vs. Madrelejos
G.R. No. 225328, March 21, 2018

FACTS: Simeon Sidera Jr., Marina Rubia, and the victim, Jovel Jacaban, were all traveling in a
jeepney when the occurrence in the case at hand happened on January 22, 2008. Two further
travelers reported a hold-up, one of them was identified as Al Madrelejos. Madrelejos' orders for
his companion to collect the passengers' belongings but, Jovel refused to give up his bag. As a
result, Jovel was shot by Madrelejos. Madrelejos and his companion then exited the jeepney,
followed by the other passengers. After being transported to the hospital, Jovel passed away from
his injuries.

ISSUE: Whether or not the crime of robbery with homicide is consummated.

RULING: Yes. The Regional Trial Court (RTC) found Madrelejos guilty of robbery with
homicide, but the Court of Appeals (CA) ruled that he should only be held guilty of attempted
robbery with homicide. The issue before the Supreme Court (SC) was whether the crime of
robbery with homicide was consummated.
The SC determined that the crime of robbery with homicide had actually been committed. If the
fact of asportation (taking the property) has been proven beyond a reasonable doubt, the
accused's conviction is justifiable even if the particular item that was the target of the robbery
was not shown as evidence. Although it may not be evident from the records whether Jovel's
luggage was taken, it was confirmed by the statements of Rubia and Sidera that the other
passengers' belongings were taken while Madrelejos and his partner were stealing the jeepney.
Madrelejos was found guilty of robbery with homicide as a result.
 People vs. Mercado
G.R. No. 218702, 0ctober 17, 2018

FACTS: Alicia Mercado and Evelyn Santos were killed, and Patrick Mercado was convicted
double murder. Evelyn said Patrick beat her and Alicia with a baseball bat before torching their house.
Patrick contested the allegations and insisted that the prosecution failed to prove his guilt beyond a
reasonable doubt.

ISSUE: Is it possible that the CA made a mistake by convicting Patrick despite the fact that the
prosecution failed to prove his guilt beyond a reasonable doubt?

RULING: No. The court found that Patrick's denial was ineffective as a defense, particularly in
considering the prosecution's evidence that clearly connected Patrick to the crime. Patrick's guilt
was shown beyond a reasonable doubt by the testimony of the prosecution witnesses, including
Evelyn's dying declarations. The prosecution's evidence was reliable even in the absence of the
baseball bat and any signs of gasoline.
The Regional Trial Court (RTC) and the Court of Appeals (CA) conducted their own evaluations
and came to a decision that the prosecution's evidence adequately proven Patrick's guilt. In
regard to this, despite the defense's claim that there was not enough evidence to condemn
Patrick, the CA did not commit a mistake.
 People vs. Abayon
G.R. No. 204891, September 2016

FACTS: According to the prosecution's testimony, Abayon and his wife Arlene argued in front of
their home on the evening of July 25, 2002. They lived in an apartment building, so their
neighbors saw the whole incident. Abayon was strangling Arlene when she screamed for help,
but Corazon Requitillo (Corazon) and her husband calmed them down. After that, Corazon
served to take Arlene's two kids and keep them safe in her apartment because Abayon was still
drunk.
At around 11:00 p.m. The same day, Abayon's neighbors saw leaking gas and overheard a hissing
sound. When they checked outside their homes, they discovered Abayon standing outside his
apartment holding an LPG gas tank.
The residence where Abayon and his neighbors reside started to catch fire around midnight on
July 26, 2002. Because of the thick smoke and heat emanating from the fire, the neighbors came
out from their own apartments. The result was that both the house and the occupants' personal
belongings entirely burned down. Along with the house owner Lourdes Chokilo, Aiza Delos
Angeles, and Zenaida Velos are died in the fire.
Expectedly, Abayon denied that he had caused the fire and raised the defense of alibi. He
admitted that he had a fight with his wife and that he left after being calmed down by his
neighbors. Abayon decided to go to his sister-in-law's house in Trece to look for his wife and
kids after realizing they were gone when he returned home. The kitchen stove and LPG tank that
had been left outdoors were brought into his apartment by him before he left. As Abayon looked
for his family, he asked Robert to watch over his house.

ISSUE: Whether or not the accused is liable for a complex crime of Arson with multiple
homicide.

RULING: According to People v. Malngan, there is no complex crime of arson and homicide
because the crime of arson either absorbs the death that results from it or is a separate crime
entirely.
In cases when there is both burning and death, it is crucial to determine the principal goal of the
perpetrator in order to decide what crime(s) was(were) committed, whether it be arson, murder,
or both homicide and murder: (a) if the main objective is the burning of the building or edifice,
but death results by reason or on the occasion of arson, the crime is simply arson, and the
resulting homicide is absorbed; (b) if, on the other hand, the main objective is to kill a particular
person who may be in a building or edifice, when fire is resorted to as the means to accomplish
such goal the crime committed is murder only; lastly, (c) if the objective is, likewise, to kill a
particular person, and in fact the offender has already done so, but fire is resorted to as a means
to cover up the killing, then there are two separate and distinct crimes committed
homicide/murder and arson.
From the body of the information filed, Abayon is charged with the crime of arson since his only
intention was to use fire to completely destroy his family's house. the deaths that resulted from
the arson should be considered part of the crime of arson and only raise the imposition of the
reclusion perpetua to death, pursuant to Section 5 of P.D. No. 1613.
 People vs. Barra
G.R. No. 198020, 10 July 2013

FACTS: A complaint was made against Joseph Barra, the appellant, charging him of
committing a special complex crime of robbery with homicide against the victim Elmer Lagdaan.
One witness claimed that he was on his way home on October 9, 2003, at 9:00 p.m., when he
observed Barra enter the house of Lagdaan (victim), which was lit with a lamp, and poked a gun
to the victim’s right forehead and demanded money. The appellant shot the victim after learning
that he did not have the money. The victim's fatal massive hemorrhage from the gunshot wound
was the cause of death.
In his defense, Barra (appellant) denied the charges against him arguing argued that the elements
for the special complex crime of robbery with homicide had not been demonstrated, particularly
the element of taking of personal property. Appellant also claimed that he was in Batangas City,
with his brother Benjamin, visiting his sister when he was arrested and brought to Camarines
Sur.

ISSUE: Whether or not Barra is guilty of robbery with homicide ( no, attempted robbery with
homicide)

RULING: The CA's decision was upheld by the SC. Barra committed an attempted robbery
with homicide. Requisites to be proven by the prosecution for appellant to be convicted of
robbery with homicide under Art. 294, are, to wit: 1) the taking of personal property is
committed with violence or intimidation against persons; 2) the property taken belongs to
another; 3) the taking is characterized by intent to gain; and 4) by reason of the robbery or on the
occasion thereof, homicide (used in its generic sense) is committed.
To extort money from the victim was the appellant's intention. The victim was shot in the head,
which led to his death, because he refused to surrender his money, which was his personal
property, to the appellant. there was an incomplete element of taking, making the crime one of
attempted robbery with homicide as opposed to the crime appellant was convicted in the RTC.
 People vs. Elizalde
G.R. No. 210434, 05 December 2016

FACTS: On June, 2005, an Information was filed against accused Arcel Lucban y Lindero, Allan
Dela Pefia, Alden Diaz, alias Erwin, charging chem with the special complex crime of
kidnapping for ransom with homicide as defined and penalized under Article 267 of the Revised
Penal Code (RPC).
That on or about 6:30 in the evening of June 17, 2003 on Dr. A. Santos St., Sucat Road,
Paranaque City and within the jurisdiction of this Honorable Court, the above-named accused,
conspiring, confederating, and mutually aiding and abetting one another, with the use of
firearms, employing force, threat, and intimidation did then and there, wilfully, unlawfully, and
feloniously take, carry away, kidnap and deprive Letty Tan y Co of her liberty against her will by
shoving her inside a red Toyota Lite Ace van with plate number ULK 341 at gunpoint and
thereafter transferred her to a Mazda XLT jitney bearing plate number CRV-299 where said
victim was later found with gunshot wounds which caused her death engaging in armed
encounter with police operatives in Tarlac City.
Sometime in April 2004, however, Antonio saw a news report on TV which showed a picture of a
wounded person involved in a shooting incident in Navotas. He instantly recognized said person
as appellant Elizalde and called a PACER agent to inform him thereof. Consequently, together
with the PACER team, he went to V. Luna Hospital where Elizalde was confined and identified
him as one of the men who dragged his wife into the red van.
A few years after, when appellant Placente was arrested in 2007, Antonio identified him as one
of the armed persons who poked a gun at him while the others dragged his wife.
Appellant Elizalde denied the charges against him, claiming that he did not know Antonio, Letty
or any of his co-accused. According to him, he went to Manila for the first time on April 15,
2003 from Samar, where he was working in a bakery, to look for his mother. He lived with his
cousin in Sta. Cruz, Manila. On the day of the alleged kidnapping on June 17, 2003, Elizalde
testified that he was in Blumentritt, Manila, selling boiled peanuts in a pushcart from 7:00 a.m. to
3:00 p.m. Afterwards, he went straight home for fear of getting lost, being in Manila for the first
time.
In addition, appellant Placente next testified and also denied knowing any of his co-accused as
well as the accusations against him. According to Placente, he came to Manila in 1982 from
Samar. On the alleged day and time of the kidnapping, he was merely working, driving a tricycle
owned by his neighbor on his way to the market in Pasig City. His job normally ends at 8:00
p.m., and on that day, he claimed that he did not go anywhere other than his daily route.
Thereafter, he parked the tricycle in front of his neighbor's house and returned the key, as he
normally did. In August 2003, he began driving a taxi. In 2005, however, he went back to Samar
with his pregnant wife and his son so that his wife can give birth there. He worked as a laborer
and a farmer until he was arrested on May 9, 2007.
On March 4, 2011, the RTC found appellants guilty beyond reasonable doubt of the special
complex crime of kidnapping for ransom with homicide. The RTC gave credence not only to the
fact that the prosecution witnesses testified in a positive, categorical, unequivocal and
straightforward manner, but also to the inherent weakness of appellants' defenses of denial and
alibi. Aside from this, the trial court further noted that the appellants' defense of denial was not
even corroborated by any credible witness.
On appeal, the CA affirmed the RTC Decision, but reduced the moral damages to Pl00,000.00. In
this regard, the CA agreed with the RTC as to the existence of conspiracy among appellants and
their cohorts. Their community of criminal design could be inferred from their arrival at
Antonio's store already armed with weapons, Placente and companions pointing their guns at
Antonio, while Elizalde and companions dragged Letty into their van. Moreover, they demanded
P20M for Letty's freedom which never materialized as she was killed during captivity by the
kidnappers before evading arrest.

ISSUES:
Whether the prosecution's witnesses are credible.
Whether the appellants' defenses of alibi and denial prosper.
Whether Antonio's positive identification of Elizalde should be given credence due to the fact
that Antonio only recognized Elizalde on television.
Whether the failure of the police officers to inform appellants of their constitutional rights is
fatal.

RULINGS:
1. Yes. The question of credibility of witnesses is primarily for the trial court to determine. Its
assessment of the credibility of a witness is conclusive, binding, and entitled to great weight,
unless shown to be tainted with arbitrariness or unless, through oversight, some fact or
circumstance of weight and influence has not been considered.
2. No. As noted by the trial court, the appellants' defenses of alibi and denial were not even
corroborated by any credible witness. Well settled is the rule that alibi and denial are inherently
weak defenses and must be brushed aside when the prosecution has sufficiently and positively
ascertained the identity of the accused. It is only axiomatic that positive testimony prevails over
negative testimony. In the instant case, it seems as if appellants urge Us to accept -hook, line, and
sinker -their self-serving statements that Elizalde was merely selling peanuts while Placente was
simply driving his neighbor's tricycle without even attempting to corroborate the same with any
supporting evidence. As aptly pointed out by the RTC, Elizalde's cousin or Placente's neighbor
could have been presented to substantiate their stories. Regrettably, appellants failed to convince.
3. Yes. Antonio actually identified Elizalde as his wife's abductor twice prior to confirming his
identity in the hospital. The day after the incident, Antonio recognized Elizalde from four ( 4)
cartographic sketches based on the descriptions given by Antonio. Thus, appellants' claim that
there was no cartographic sketch of Elizalde made after the crime has no basis. Thereafter,
Antonio again recognized Elizalde on television prompting him to immediately call the PACER
agents. Verily, the Court cannot give credence to appellants' assertion that Elizalde' s
identification at the hospital was marked by suggestiveness for as clearly narrated, it was
Antonio who first recognized Elizalde on television and who instantly contacted the PACER
agents, not the other way around.
4. No. As for the alleged nullity of the proceedings due to the absence of any showing that the
police officers informed appellants of their constitutional rights, the Court sustains the CA' s
ruling that even assuming said failure to inform, the same is immaterial considering that no
admission or confession was elicited from them. As previously discussed, their guilt was
established by the strength of the prosecution witnesses' testimonies.