People v. Aquino
REITERATIONFacts
The Antecedents: On February 28, 1966, the victim, Victoria Costes Vda. de Mendinueto, an 84-year-old woman, was robbed of P32.00 in her house in Binalonan. During the commission of the robbery, she was inflicted with a deep stab wound which caused her death. Procedural History: Ruperto Aquino, Manuel Mangsat, and Jose Fabro were charged with robbery with homicide. Manuel Mangsat pleaded guilty and was sentenced to reclusion perpetua. Jose Fabro was discharged and utilized as a state witness. The trial proceeded against Ruperto Aquino. The trial court found Aquino guilty beyond reasonable doubt and sentenced him to reclusion perpetua, to indemnify the heirs of the deceased, and to pay costs. The Petition: The accused-appellant, Ruperto Aquino, appealed his conviction, arguing that the evidence used against him was doubtful and inadmissible.
Issue(s)
Whether the guilt of the accused-appellant Ruperto Aquino for the crime of robbery with homicide was established beyond reasonable doubt. Whether the testimony of a discharged co-accused (state witness) and the extra-judicial confession of another co-accused are sufficient to sustain a conviction. Whether the defense of alibi presented by the accused-appellant is tenable. Whether the commission of the crime in the dwelling of the victim is an aggravating circumstance.
Ruling
The judgment of conviction is affirmed, with the modification that the indemnity to be paid to the heirs of the deceased is increased to P12,000.00. The penalty of reclusion perpetua imposed by the trial court stands.
Ratio Decidendi
On the issue of whether the guilt of the accused-appellant Ruperto Aquino for the crime of robbery with homicide was established beyond reasonable doubt: The Court affirmed the conviction, finding that Aquino's guilt was duly established beyond reasonable doubt. This conclusion was based on the positive testimony of Jose Fabro, who was discharged and utilized as a state witness. This testimony was further corroborated by the extra-judicial confession of Manuel Mangsat, another co-accused who pleaded guilty to the same crime and was serving a sentence of reclusion perpetua. The Court found no valid ground to set aside the conviction, emphasizing the corroborative nature of the evidence presented by the prosecution. The trial court's careful appraisal of Fabro's testimony, despite him being a co-conspirator, was deemed sufficient for conviction when corroborated. On the issue of whether the testimony of a discharged co-accused (state witness) and the extra-judicial confession of another co-accused are sufficient to sustain a conviction: The Court held that the testimony of Jose Fabro, even if considered that of an accomplice or co-conspirator, is admissible and competent. The rule is that such testimony, while coming from a "polluted source" and subject to grave suspicion, is sufficient to warrant conviction if corroborated. In this case, Fabro's testimony was corroborated by Mangsat's confession and other supportive evidence. The Court also noted that Aquino's own sworn statement corroborated Fabro's testimony regarding an attempt to bribe Fabro into taking responsibility, which the Court considered as indicative of a guilty conscience. On the issue of whether the defense of alibi presented by the accused-appellant is tenable: The Court correctly dismissed Aquino's defense of alibi. The trial court found the alibi weak because the witnesses who testified in its favor were biased and interested parties, namely his mother, wife, and brother. Furthermore, the Court noted that the alibi had no force considering that Aquino and the victim were neighbors, making it easy for him to commit the crime and then return home to feign sleep. The positive and direct evidence of his participation in the crime outweighed the unconvincing alibi. On the issue of whether the commission of the crime in the dwelling of the victim is an aggravating circumstance: The Court noted motu proprio that the commission of the crime was aggravated by the fact that it was committed in the dwelling of the victim, as provided for under Article 14, paragraph 3 of the Revised Penal Code. In the absence of any mitigating circumstances, this aggravating circumstance would have justified the imposition of the maximum penalty of death under Article 294, paragraph 1 in relation to Article 63 of the same Code. However, due to the failure to obtain the necessary number of votes for the imposition of the death penalty, the penalty next lower in degree, which is reclusion perpetua, as imposed by the trial court, was affirmed.
Main Doctrine
The conviction for robbery with homicide is affirmed based on the corroborated testimony of a state witness and the extra-judicial confession of a co-accused. The commission of the crime in the victim's dwelling was noted as an aggravating circumstance, though the death penalty could not be imposed due to insufficient votes.