People v. Patalin, Jr., et al, G.R. No. 110878, 370 Phil. 200 (1999)
### Facts:
**Initial Criminal Incident:**
– On the evening of August 11, 1984, at around 7:30 PM in Barangay Lumanay, Lambunao, Iloilo, Alfonso Patalin, Jr. called out to Reynaldo Aliman from outside his fenced perimeter and requested entry.
– Accompanied by Alex Mijaque and two others, Patalin was let in by Reynaldo.
– Upon entry, Patalin shone a flashlight on Reynaldo, allowing Mijaque to hack Reynaldo twice, causing serious injuries.
– Corazon Aliman and Josephine Belisario witnessed the incident from their balcony, whereupon Mijaque forced his way into their home, stole properties worth ₱700, and subsequently dragged Corazon and Josephine to a nearby house.
**Criminal Case No. 18305 (Robbery with Multiple Rape):**
– Patalin, Mijaque, Ras, and their accomplices invaded Jesusa Carcillar’s house, robbing the household of valuables worth ₱6,500 and sexually assaulting the following victims:
– Juliana Carcillar (raped twice by Mijaque)
– Rogelia Carcillar (raped by Mijaque and unknown accomplice)
– Josephine Belisario (raped by Mijaque)
– Perpetua Carcillar (raped by Ras after Patalin’s failed attempt).
**Procedural Posture:**
– The accused-appellants were arraigned with pleas of “not guilty.”
– The trial court rendered a joint judgment convicting:
– Patalin and Mijaque for robbery with physical injuries in Criminal Case No. 18376.
– Patalin, Mijaque, and Ras for robbery with multiple rape in Criminal Case No. 18305.
### Issues:
1. **Identification and Credibility:**
– Were the accused-appellants correctly identified by the prosecution witnesses?
2. **Legitimacy of Arrests:**
– Should the conviction of Patalin and Mijaque be invalidated due to their arrest without a warrant?
3. **Appropriate Penalty:**
– Is the imposition of the death penalty on the accused-appellants valid given the ratification of the 1987 Constitution, which abolished the death penalty?
### Court’s Decision:
**Identification and Credibility:**
– The Court upheld the trial court’s assessment of the witnesses’ credibility, noting their direct interaction with the assailants and absence of ill motive.
– Positive identification by multiple witnesses during a protracted and well-lit encounter was deemed credible.
**Legitimacy of Arrests:**
– The objection regarding the warrantless arrest was dismissed as it was not raised prior to the plea; therefore, any defect was deemed waived.
**Appropriate Penalty:**
– The death penalty initially imposed was reduced to reclusion perpetua, consistent with the abolition of the death penalty in the 1987 Constitution.
– Revised awards included indemnification for each count of rape and other forms of damages due to the severity of the crimes.
### Doctrine:
1. **Assessment of Witness Credibility:**
– The trial court’s first-hand evaluation of witness testimonies carries significant weight unless proven otherwise.
2. **Warrantless Arrests:**
– Objections to warrantless arrests must be raised before arraignment; failure to do so constitutes waiver of the issue.
3. **Retroactive Application of Favorable Penal Laws:**
– Article 22 of the Revised Penal Code mandates retroactive application of laws that favor the accused, barring subsequent reimposition without express legislative intention for retroactivity.
### Class Notes:
– **Key Concepts:**
– Positive identification and credibility assessment.
– Procedural waiver related to warrantless arrests.
– Retroactive application of favorable penal provisions (Article 22, Revised Penal Code).
– **Statutory Provisions:**
– **Article 22, Revised Penal Code**: “Penal laws shall have a retroactive effect insofar as they favor the person guilty of a felony, who is not a habitual criminal…”
– **Sec. 19 (1), Article III, 1987 Constitution**: Abolished the death penalty with potential for future legislative reinstatement.
– **Application:**
– Positive ID in a crime with multiple perpetrators must be detailed and corroborated.
– Legal objections regarding arrest procedures must be timely.
– Favorable penal laws, upon ratification, immediately apply to ongoing cases offering the same protections prior to actual imposition of penalties.
### Historical Background:
– **Contextual Background:**
– The 1987 Philippine Constitution abolished the death penalty after the Marcos regime’s fall, reflecting a shift towards more humane criminal justice policies. The restoration in 1994 indicated a legislative response to escalating heinous crimes, balanced against constitutional mandates involving penal reforms.
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