G.R. No. L-32512 March 31, 1980
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARMIDA RODRIGUEZ DE PASCUAL, defendant-appellant.

FACTS

The accused, Armida Rodriguez de Pascual, was charged with Robbery with Homicide. The information alleged that on June 11, 1970, in Caloocan City, with intent to gain, she killed Juliana Sy by hitting her with a bottle and cutting her neck with a knife, and took P6,000.00 from the victim. The crime was aggravated by alleged cruelty through dismemberment of the corpse and by craft in luring the victim. After trial, the Circuit Criminal Court of Pasig sentenced the accused to death and ordered her to pay indemnity and damages. The accused appealed the judgment.
The prosecution evidence established that the 17-year-old victim, Juliana Sy, was tasked to deposit the day’s grocery proceeds. She told her mother she would be accompanied by the accused, their neighbor. The victim disappeared. Her dismembered remains were later discovered. The accused was pointed out by the victim’s mother, who noted injuries on the accused. The accused later led police to where body parts were hidden. An extra-judicial confession was executed by the accused. Police recovered P750.00 from her bag and P810.00 hidden in her apartment, which the victim’s mother identified as part of the stolen money. A bottle and a knife were also recovered from the accused’s residence.

ISSUE

The core issue is whether the guilt of the accused for the crime of Robbery with Homicide was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction, with a modification on the civil indemnity. The Court found the evidence of guilt overwhelming. The accused’s extra-judicial confession was deemed voluntary and corroborated by physical evidence. The recovery of portions of the stolen money from her possession and her act of leading police to the concealed body parts constituted corroborative acts consistent with guilt. The defense’s claim of an uncorroborated alibi was rightly rejected by the trial court for being weak and unsubstantiated.
Regarding the aggravating circumstances, the Court ruled that cruelty could not be appreciated merely from the dismemberment of the corpse, absent proof it was done while the victim was still alive. However, the aggravating circumstance of craft was properly considered. The evidence showed the accused deceived the victim into coming to her apartment under the pretext of accompanying her to the bank, thereby facilitating the commission of the crime. The award of civil indemnity was modified, reducing it by P3,000.00, as this amount represented unrecovered checks that could not have been encashed by the accused, resulting in a final indemnity of P13,440.00. The penalty of death was affirmed.