This case has been cited 7 times or more.
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2004-04-14 |
YNARES-SATIAGO, J. |
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| The complex crime of robbery with homicide arises when, by reason of or on the occasion of a robbery, by means of violence against or intimidation of persons, a person is killed.[29] To sustain a conviction for this special complex crime, the original criminal design of the culprit must be robbery (originally, there must be intent to gain), and the homicide is perpetrated with a view to the consummation of the robbery (by reason or on the occasion of the robbery).[30] | |||||
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2004-01-15 |
DAVIDE JR., CJ. |
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| It has been held that price or reward is evidence of conspiracy.[39] But the same was not established by competent proof in this case. The extrajudicial confession[40] and the newspaper reports[41] adduced by the prosecution, which both contained Sayaboc's statement pointing to Marlon Buenviaje as the one who paid him P100,000 to kill Galam, are inadmissible in evidence. The first, as earlier stated, was executed in violation of Sayaboc's constitutional rights. The second are hearsay, since the authors of such reports were not presented as witnesses to affirm the veracity thereof.[42] | |||||
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2004-01-13 |
PANGANIBAN, J. |
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| Regarding his alleged uncounselled admission, suffice it to stress that it was not given during a custodial investigation and, certainly, not to police authorities. Custodial investigation has been defined as any questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of freedom of action in any significant way.[21] We have ruled previously that constitutional procedures on custodial investigation do not apply to a spontaneous statement that is not elicited through questioning by the authorities, but is given in an ordinary manner.[22] | |||||
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2003-08-12 |
VITUG, J. |
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| In this case, the circumstances established, in the considered view of the Court, would adequately support the finding of guilt pronounced by the trial court. (1) On 23 May 1991, the tricycle belonging to Hernani Tancinco was stolen; (2) the tricycle was later found in the house of appellant Llavore, and no satisfactory reason was given to explain his possession thereof;[16] (3) some parts of the vehicle had been removed, changed, or replaced and the motor and chassis number had been defaced; (4) on the occasion of the unlawful taking of the property, Danilo Malata, then driving the tricycle, was stabbed to death; (5) the postmortem examination conducted by Dr. Guanzon on 24 May 1991 showed seven stabbed wounds on different parts of the victim's body; and (6) a sack containing the missing parts of the tricycle were found about two kilometers away from the house of appellant's father in Hacienda El Paso. | |||||
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2003-07-17 |
PER CURIAM |
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| The circumstances constitute an unbroken chain which leads to the reasonable conclusion that the trial court could not have erred in finding appellants to have been the responsible culprits. The recovery of the loot from appellants at the time of their arrest moreover gives rise to the legal presumption of guilt. The absence of an explanation on how appellants have come into the possession of the personal effects of the victim gives rise to reasonable presumption that they, too, could have been the authors of the crime.[10] | |||||
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2000-06-08 |
QUISUMBING, J. |
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| We note that Section 3 of Rule 133 of the Rules[30] requires that an extrajudicial confession made by an accused shall not be sufficient ground for conviction, unless corroborated by evidence of corpus delicti. Corpus delicti is the body of the crime and, in its primary sense, means a crime has actually been committed.[31] Applied to a particular offense, it is the actual commission by someone of the particular crime charged.[32] In this case, aside from the extrajudicial confessions, the police found the stolen goods, the murder weapons, and the dead bodies, thereby conclusively establishing the needed corroborating evidence of corpus delicti. | |||||
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2000-03-07 |
QUISUMBING, J. |
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| The fatal stabbing of Virginia Talens occurred at around 3:00 a.m. of March 6, 1992. Appellant hastily abandoned his house in Barrio San Nicolas, Mexico, Pampanga, his residence since childhood, on that very date. Appellant was nowhere when his co-worker and barriomate, Eduardo Bagtas, came to appellant's house to fetch him for work at around 6:30 to 7:00 a.m. of March 6, 1992. [13] Appellant also abandoned his job as a painter in Sta. Ana, Pampanga, on March 6, 1992, the date of the crime, leaving behind an unfinished painting project. He was not seen again from said date. [14] Police investigators found human bloodstains on the front door of appellant's house, on his clothing, and on his yellow slippers after the victim was killed. [15] Despite efforts of the police to find appellant as the principal suspect, a fact known to appellant's family and neighbors, appellant did not present himself to the authorities. [16] Appellant was apprehended only a full six (6) months after the date of the crime, following his confinement in a hospital in Arayat, Pampanga because he was sideswiped by a Victory Liner bus in Arayat. [17] When hospitalized, appellant used the alias Rommel Salas, instead of his true name Elmer Salas. [18] These circumstances denote flight, which when unexplained, has always been considered by the courts as indicative of guilt. [19] | |||||