People v. Dacio
REITERATIONFacts
The Antecedents: On March 21, 1951, Uy Moy, a store owner, was robbed and killed in his store in Isabela. Three armed men entered the store, demanded money, took the contents of a drawer, tied Uy Moy's hands, and then one of the robbers shot Uy Moy with a carbine, causing his death. Before dying, Uy Moy mentioned that a woman named Felisa Marte had threatened him a few days prior due to a credit dispute. Procedural History: The accused, Buenconsejo Dacio, along with Ceferino Feliciano and Carlito Ortega, were charged with robbery with homicide. Dacio made confessions admitting his participation and identifying Feliciano as the shooter. He also pleaded guilty to the charge of robbery with homicide multiple times. However, when arraigned in the Court of First Instance, he pleaded not guilty to robbery with homicide, prompting the court to enter a plea of not guilty for him. The prosecution presented evidence including confessions, eyewitness testimony from Jao Ka Chiong, and medical testimony from Dr. Alejandro. Dacio's counsel presented a statement from Jao Ka Chiong. The trial court found Dacio guilty of robbery with homicide. The Petition: The defendant-appellant appealed the judgment, arguing that the judge should have warned him of the effects of his plea of guilty and that his counsel should have advised him to testify to show lack of participation in the homicide, admitting only participation in the robbery.
Issue(s)
Whether the trial court erred in entering a plea of not guilty for the appellant after he had previously pleaded guilty to robbery with homicide. Whether the appellant is liable for robbery with homicide despite his claim of only participating in the robbery and not the killing. Whether the appellant's confessions and plea of guilty are sufficient to sustain a conviction for robbery with homicide.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, finding the appellant guilty of robbery with homicide, but reduced the indemnity for the money taken from P400 to P100. The sentence of reclusion perpetua was upheld.
Ratio Decidendi
On the appellant's plea and subsequent entry of 'not guilty': The Court found no merit in the argument that the judge should have warned the appellant of the effects of his plea of guilty or advised him to testify. The Court held that when an accused appears with counsel, it is the counsel's duty to advise the accused. The fact that Dacio made confessions and pleaded guilty multiple times, even if a plea of not guilty was later entered, was considered as evidence. The Court noted that no benefit could have been gained by taking the witness stand if the intention was to fabricate a defense, especially in the face of prior confessions. On the appellant's liability for robbery with homicide: The Court reiterated the principle that all persons who enter into a conspiracy to commit robbery with homicide are liable for the crime, including the homicide, unless they endeavored to prevent the homicide. The Court found no indication in Dacio's confessions or the evidence that he attempted to prevent the homicide. Therefore, his liability extended beyond robbery to robbery with homicide. On the sufficiency of evidence: The Court found the evidence sufficient to prove the guilt of the defendant beyond reasonable doubt. The appellant's confessions (Exhibits "B" and "D") admitted his presence and participation in the robbery, and identified Ceferino Feliciano as the one who shot Uy Moy. The eyewitness testimony of Jao Ka Chiong corroborated the identification of Dacio as one of the robbers. The medical testimony established the cause of death. The Court concluded that the judgment appealed from was fully justified by the evidence presented.
Main Doctrine
A plea of guilty to robbery with homicide, even if later withdrawn or entered as not guilty, can be considered as evidence of guilt, especially when corroborated by other evidence. Furthermore, all persons who enter into a conspiracy to commit robbery with homicide are liable for the crime, including the homicide, unless they endeavored to prevent the homicide.