People v. Doble
REITERATIONFacts
The Antecedents: On June 14, 1966, ten armed men committed a bank robbery in band, with multiple homicide, multiple frustrated homicide, and assault upon agents of persons in authority, at the Prudential Bank and Trust Company in Navotas, Rizal. Five accused were brought to trial, two were acquitted, and three, appellants Cresencio Doble, Simeon Doble, and Antonio Romaquin, were sentenced to death by the trial court. The crime involved a motor banca proceeding from Manila to Navotas, armed men disembarking, shots being heard, and the perpetrators returning to the banca with what appeared to be "bayongs." Among the fatalities were law enforcement agents and a market collector, with several others injured. The bank, with unusual midnight to 8:00 a.m. banking hours, was entered by armed men who demanded the vault key, fired upon the vault until it opened, and then took P10,439.95 from the teller cages. Police officers on duty near the bank heard shots and witnessed some of the casualties. Procedural History: The Court of First Instance of Rizal imposed the death penalty on appellants Cresencio Doble, Simeon Doble, and Antonio Romaquin. The case was elevated to the Supreme Court for automatic review. The Petition: Appellants argued that their extrajudicial statements were inadmissible due to force, intimidation, and violation of their rights to counsel and against self-incrimination. Simeon Doble's conviction was based on his house being a meeting place for the malefactors.
Issue(s)
Whether Simeon Doble is guilty as a principal in the crime of robbery in band. Whether the extrajudicial statements of Cresencio Doble and Antonio Romaquin are admissible in evidence. Whether Cresencio Doble and Antonio Romaquin are guilty as co-principals or accomplices in the crime of robbery in band.
Ruling
The Supreme Court acquitted Simeon Doble. It modified the conviction of Cresencio Doble and Antonio Romaquin, finding them guilty only as accomplices for the crime of robbery in band, and imposed an indeterminate penalty. The judgment of the trial court was affirmed in all other respects.
Ratio Decidendi
On the guilt of Simeon Doble: The Court found no sufficient evidence to establish Simeon Doble's guilt beyond reasonable doubt. The evidence showed only that the malefactors met in his house to discuss the plan to rob the bank. This circumstance, standing alone, did not prove his participation in the perpetration of the robbery, nor did he take direct part therein or induce others to commit it. His mere presence at the meeting, without active participation in the talks or cooperation in the commission of the robbery, did not make him a co-conspirator. His statement that he had not yet received his share was interpreted as an indication that he had nothing to do with the commission of the crime and therefore did not receive any share of the fruits thereof. His physical condition, a foot injury, also suggested he could not have been of help to the malefactors. Therefore, he was acquitted. On the admissibility of extrajudicial statements: The Court held that the extrajudicial statements of Cresencio Doble and Antonio Romaquin were admissible. Their claims of maltreatment and coercion were unsubstantiated by medical certificates or other corroborating evidence. The details in their statements, while containing discrepancies, generally fit together, indicating a degree of freedom in their narration. The fact that another co-accused, Celso Aquino, gave his statement without violence, and that the appellants themselves virtually confirmed their statements in court, further supported their voluntariness. The argument that the killing of a suspect instilled fear was dismissed as the killing occurred after their interrogation. Furthermore, the right to counsel during custodial interrogation was not yet a constitutional grant in 1966, when the statements were taken, as it was only provided for in the 1973 Constitution. The right against self-incrimination was also not violated, as the statements were found to be voluntary, and voluntariness is presumed. On the liability of Cresencio Doble and Antonio Romaquin: The Court ruled that Cresencio Doble and Antonio Romaquin were guilty only as accomplices, not co-principals, for the crime of robbery in band. While they cooperated by providing the banca used for the robbery and getaway, their participation was not indispensable. The robbery could have been committed even without their assistance. Cresencio's role was limited to looking for a banca, and Romaquin provided it, with the amount received by Romaquin likely representing payment for the banca rental and cooperation, not a share of the loot. The measures taken to prevent Romaquin's escape indicated he was not fully trusted as a confederate. Cresencio's note asking Romaquin not to reveal names and the P41.00 he received from Romaquin suggested some material assistance but not that of a principal. Their complicity was limited to the criminal design to rob, not the killings that occurred, as they were in the banca and could not have prevented the violence. Thus, they were classified as accomplices.
Main Doctrine
The Court acquitted Simeon Doble for lack of evidence of culpable participation. Appellants Cresencio Doble and Antonio Romaquin were found guilty as accomplices for robbery in band, not as co-principals, due to their non-indispensable cooperation in providing the getaway banca, and their extrajudicial statements were admitted as voluntary despite claims of coercion, as the right to counsel during custodial interrogation was not yet a constitutional grant in 1966.