327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Could
the lack of direct evidence in a robbery-homicide case still lead to a
conviction when based solely on circumstantial evidence?
People
of the Philippines vs. Jay Godoy Mancao
G.R.
No. 228951, July 17, 2019
Facts
of the Case:
In
this case, Jay Godoy Mancao was charged with robbery with homicide
following an incident on September 2, 2007, in Davao City, where Peter
Ray Garcia Enriquez, a 17-year-old, was killed. The prosecution alleged that
Mancao, armed with bladed weapons, violently grabbed Enriquez, stole his
belongings—including a Nokia 6630 cellphone, silver bracelet, necklace, and
wallet—then fatally stabbed him. The case was filed in Regional Trial
Court-Branch 8, Davao City, where Mancao pleaded not guilty.
During
the trial, the prosecution’s witness, Manuel Bernido Jr., testified that
he saw Mancao stab the victim in the neck and drag his body into an alley.
Other key testimonies came from SPO2 Kelvin Magno, who recounted how
police followed a blood trail to Mancao’s residence and eventually arrested him
with the victim's silver necklace in his possession. The victim’s father, Pedro
Enriquez, confirmed that the necklace belonged to his son.
Mancao’s
defense was alibi, stating he was tending his mother’s land in another
province at the time. However, the trial court found him guilty based on
circumstantial evidence, sentencing him to reclusion perpetua for robbery
with homicide. Mancao appealed to the Court of Appeals, challenging
the credibility of the witnesses and the sufficiency of the circumstantial
evidence.
The
Court of Appeals affirmed the conviction on September 27, 2016,
with modifications on the damages awarded.
Issue:
Did
the Court of Appeals err in affirming Mancao’s conviction for robbery with
homicide, despite the reliance on circumstantial evidence?
Decision
of the Supreme Court:
The
Supreme Court affirmed the Court of Appeals' decision, ruling
that the conviction based on circumstantial evidence was proper. While there
were no direct witnesses to the actual robbery, the Court held that circumstantial
evidence could suffice when it creates an unbroken chain leading to a
reasonable conclusion of guilt.
The
Court emphasized that the following factors were enough to prove Mancao's guilt
beyond a reasonable doubt:
- Eyewitness
account from
Bernido Jr., who saw Mancao stab the victim.
- The discovery
of the victim’s necklace in Mancao’s possession when he was arrested.
- The lack
of justification for Mancao’s possession of the stolen item.
The
Court noted that intent to rob was clearly established as the motive
behind the homicide, reinforcing that the killing was committed in relation to
the robbery.
Dispositive
Portion:
The
Supreme Court denied the appeal and upheld the conviction of Jay Godoy
Mancao for robbery with homicide, imposing the penalty of reclusion
perpetua. Mancao was also ordered to pay:
- P75,000.00
as civil indemnity,
- P75,000.00
as moral damages,
- P75,000.00
as exemplary damages, and
- P50,000.00
as temperate damages,
with a 6% interest per annum from the finality of the judgment until fully paid.
Should
circumstantial evidence be given the same weight as direct evidence when
determining guilt in serious crimes like robbery with homicide?
Important
Doctrines:
- Circumstantial
Evidence Sufficiency (Rule 133, Section 4, Rules of Court)
- Circumstantial
evidence is sufficient for conviction when more than one circumstance is
proven, and the combination leads to a moral certainty of guilt beyond
reasonable doubt.
- Possession
of Stolen Property (Rule 131, Section 3(j), Rules of Court)
- A
person found in possession of stolen property is presumed to be the one
who took it unless proven otherwise. In this case, Mancao’s possession of
the victim’s necklace supported his conviction.
- Robbery
with Homicide (Article 294, Revised Penal Code)
- A
conviction for robbery with homicide requires that the intent to rob must
be the principal objective, and the homicide merely incidental to the
robbery. In this case, the killing occurred on the occasion of the
robbery, fulfilling the elements of the crime.
Classification
of the Case:
Criminal
Law – Robbery with
Homicide under the Revised Penal Code.
From
<https://chatgpt.com/g/g-ipZC0xKZ1-case-digest/c/66eebc5d-cab0-800a-8add-3882b938f7b6>
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📚 INTRODUCTION (by Expert
Philippine Law Professor):
Welcome, future lawyers! In today’s quizzer, we will explore
a compelling case decided by the Supreme Court involving Criminal Law,
specifically the complex crime of Robbery with Homicide. This quizzer
focuses on the case titled:
🔹 People of the
Philippines vs. Jay Godoy Mancao
🔹 G.R. No. 228951
🔹 Promulgated on July
17, 2019
This case involves the brutal killing of a 17-year-old boy,
Peter Ray Garcia Enriquez, who was stabbed and robbed in the early hours of the
morning. The accused, Jay Godoy Mancao, was convicted based largely on
circumstantial evidence and the presumption that a person found in possession
of recently stolen property is presumed to be the perpetrator of the crime.
The Supreme Court upheld the conviction, affirming that
circumstantial evidence may be enough to establish guilt beyond reasonable
doubt when direct evidence is lacking.
📝 Answer key will be
provided at the end of the video. Now, let's proceed to your quiz!
🔥 10 EASY-HOTS MULTIPLE
CHOICE QUESTIONS:
1. What type of crime was Jay Godoy Mancao charged
with in the case?
A. Murder
B. Theft
C. Robbery with Homicide
D. Qualified Robbery
2. What was the victim doing just before the crime
occurred?
A. Eating at a restaurant
B. Talking to someone
C. Texting while waiting for a jeepney
D. Walking to school
3. What piece of evidence was found in the possession
of the accused at the time of arrest?
A. The victim’s wallet
B. A bloodied weapon
C. The victim’s silver necklace
D. The victim’s cellphone
4. Why did the Court reject the accused's alibi?
A. It was inconsistent with the time of death
B. He had no supporting witnesses
C. It was contradicted by direct eyewitness testimony
D. It failed to overcome circumstantial evidence
5. What was the main legal issue in the case?
A. Whether the accused acted in self-defense
B. Whether robbery was proven by eyewitnesses
C. Whether circumstantial evidence can lead to conviction
D. Whether the accused knew the victim
6. What doctrine allowed the Court to presume Mancao
was the perpetrator?
A. Doctrine of Dying Declaration
B. Chain of Custody Rule
C. Presumption from possession of stolen property
D. Totality of Circumstances Doctrine
7. What was the penalty imposed on the accused?
A. Life imprisonment
B. Death
C. Reclusion perpetua
D. Arresto mayor
8. Who testified that they saw the accused stab the
victim?
A. A barangay official
B. The victim’s friend
C. A nearby resident
D. Manuel Bernido Jr.
9. What did the accused allegedly use to clean the
crime scene?
A. A hose
B. A mop
C. A bucket
D. A dipper with water
10. How did the police track down the accused after
the crime?
A. Through CCTV footage
B. By tracing his cellphone
C. By following a trail of blood
D. Through a tip from the victim’s family
CLICK LINK BELOW TO GO TO TOP 10 DOCTRINES
From <https://chatgpt.com/g/g-ipZC0xKZ1-case-digest/c/66eebc5d-cab0-800a-8add-3882b938f7b6>
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