People of the Philippines vs. Larry Laurente y Bejasa, Melvin Dagudog, and Richard Disipulo
**Facts:**
1. **Incident Date and Events:**
– On February 14, 1994, Herminiano G. Artana, a taxi driver, was allegedly held up and killed by three men while inside his taxi along F. Concepcion St., Pasig, Metro Manila.
– Witness Myra Guinto saw three men leave the taxi and rush past her towards a jeepney.
2. **Investigation:**
– SPO1 Crispin Pio from Pasig Police Station responded to the scene, finding Artana dead inside the taxi.
– A brown wallet containing an SSS ID belonging to Larry Laurente was found inside the taxi, along with a suspect leather belt.
3. **Arrest:**
– Laurente was arrested the next day, February 15, 1994, after police identified him using the SSS ID records.
– Laurente was not represented by counsel during his police investigation but allegedly admitted involvement in the crime.
4. **Procedural Posture:**
– Laurente was charged with Highway Robbery with Homicide under P.D. No. 532. The information was later amended to include Melvin Dagudog and Richard Disipulo.
– During the trial, Laurente entered a plea of “not guilty”.
– At the trial, the prosecution presented four witnesses: SPO1 Pio, Myra Guinto, Felicitas Matematico (the victim’s daughter), and Dr. Emmanuel Arañas (a medico-legal officer).
– Laurente offered an alibi, stating he was at home drinking with Dagudog and Disipulo at the time of the crime, and claimed they took his wallet.
5. **Conviction:**
– The Regional Trial Court of Pasig found Laurente guilty and sentenced him to death. The case was brought to the Supreme Court for automatic review due to the death penalty.
**Issues:**
1. **Applicability of P.D. No. 532:**
– Whether Laurente’s action constitutes Highway Robbery with Homicide under P.D. No. 532, given the specific requirements for such classification to prevent depredations by outlaws against any person on highways.
2. **Validation of Positive Identification:**
– Whether Myra Guinto’s identification of Laurente as one of the robbers was reliable.
3. **Conviction Under Article 294(1) of the Revised Penal Code:**
– Assuming the invalidity of the charge under P.D. No. 532, whether Laurente can be convicted under Article 294(1) (Robbery with Homicide) of the Revised Penal Code instead.
4. **Admissibility of Confession without Counsel:**
– Effect of Laurente’s confession obtained without counsel during custodial investigation.
5. **Proof of Robbery:**
– Whether the prosecution provided sufficient evidence to prove robbery.
**Court’s Decision:**
1. **Applicability of P.D. No. 532:**
– The Court held that P.D. No. 532 does not apply in this case because it targets indiscriminate depredations on highways by outlaw bands—not isolated incidents aimed at specific victims.
2. **Validation of Positive Identification:**
– The Court upheld the credibility of Myra Guinto’s testimony. Her positive identification of Laurente was deemed credible given her direct observation at the well-lit crime scene and lack of supporting evidence of any ill motive.
3. **Conviction Under Article 294(1):**
– The Court reaffirms that the crime committed aligns more appropriately with Robbery with Homicide under Article 294(1) of the Revised Penal Code. It modifies the conviction to Homicide due to a lack of concrete evidence of robbery.
4. **Admissibility of Confession without Counsel:**
– The Court disregarded Laurente’s confession given the absence of counsel at his custodial investigation, which violated constitutional rights.
5. **Proof of Robbery:**
– The Court found the evidence of robbery insufficient. Statements from witnesses regarding the victim’s earnings were considered hearsay, and the prosecution did not adequately demonstrate the physical act of unlawful taking.
**Doctrine:**
1. **P.D. No. 532 Interpretation:**
– For a conviction of Highway Robbery under P.D. No. 532, there must be intent to indiscriminately rob travelers on the highway, not aimed at predetermined or specific victims.
2. **Robbery with Homicide:**
– It is not enough to have a dead body with injuries; the unlawful taking of property must be proven independently and precisely.
**Class Notes:**
– **Elements of Robbery with Homicide (Article 294(1), RPC):**
1. Unlawful taking.
2. Using violence or intimidation.
3. Homicide committed by reason or occasion of the robbery.
– **Constitutional Rights During Custodial Investigation (Section 12, Article III, 1987 Constitution):**
– Right to be informed of the right to remain silent and right to counsel.
– Waiver of these rights must be in writing and in the presence of counsel.
– **Competency and Reliability of Eyewitness Testimony:**
– Eyewitness identification should be credible and without evidence of improper motives.
**Historical Background:**
– P.D. No. 532, enacted during the Martial Law era, aims to deter highway robberies and protect travelers. However, the specific elements required for a crime to qualify under this decree differ markedly from simple robbery or homicide cases in terms of indiscriminate targeting and the nature of perpetration on highways by outlaw bands.
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