People v. Repulloso
REITERATIONFacts
The Antecedents: Reynaldo Repulloso, Victor Villar, Jr., and Elmer Barcelon, who worked at the railroad station, were involved in a drinking spree with others. Repulloso introduced Kare as a new member of his gang and displayed a knife. Later, Repulloso, Villar, and others boarded a trimobile. Barcelon and Agravante jumped off after hearing Villar state an intention to extort money from the driver. Repulloso and Villar remained. The trimobile proceeded, and the driver was stabbed and robbed of five pesos and his sweater. Around the same time, Domingo Estay, the fourteen-year-old son of the trimobile owners, was driving the same trimobile. He was flagged down by Repulloso and companions, subsequently stabbed by two unidentified persons, divested of five pesos and his sweater, and left mortally wounded. He was found by police, identified his assailants as wearing a T-shirt with an A-Go-Go design, and was brought to the hospital. The next morning, Repulloso confessed to Barcelon that he and Villar had stabbed someone. Doctor Honesto V. Marco certified that Domingo Estay died due to hemorrhage caused by stab wounds in the chest and abdomen, inflicted by a double-bladed instrument. The abdominal wound was fatal, and the chest wound contributed to death. Procedural History: An information for robbery with homicide was filed against Villar and Repulloso. Repulloso was arrested, but Villar was never apprehended. Statements were executed by Elmer Ordoñez, William Agravante, Pedro Estay, Detectives Romeo S. Mandigma and Tomas M. Rentoy. Repulloso waived the second stage of the preliminary investigation, and a new information was filed. After trial, the Court of First Instance of Camarines Sur convicted Repulloso of robbery with homicide, sentencing him to reclusion perpetua and ordering him to indemnify the heirs of Domingo Estay. The Petition: Reynaldo Repulloso appealed the decision, contending that the trial court erred in not believing his testimony and in finding him guilty beyond reasonable doubt. He claimed Villar stabbed the victim and warned him not to reveal this, leading him to flee home. He admitted this version was different from his police statement and denied confessing to Barcelon. He stated the knife he showed belonged to Kare.
Issue(s)
Whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt of robbery with homicide. Whether the aggravating circumstances of nocturnity and abuse of superiority were present.
Ruling
The judgment of the trial court is affirmed with the modification that the indemnity should be increased to twelve thousand pesos. Costs against the appellant.
Ratio Decidendi
On Whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt of robbery with homicide: The Supreme Court affirmed the conviction, finding that Repulloso's guilt was established to a moral certainty. His own admission that he was with Villar when the latter stabbed the driver, coupled with his confession to his intimate friend Barcelon that he and Villar stabbed the driver, were decisive. The Court reasoned that if Repulloso had not made such a confession, Barcelon, as a close friend, would have testified to that negative fact. The Court emphasized that admissions deliberately made by a party charged with a crime are always admissible to show guilt, citing People vs. Hernane. The Court found that Repulloso's involvement as a co-conspirator or co-principal by direct participation was evident from his admissions, rendering the specific weapon used immaterial. His claim of fear of Villar was deemed an insufficient excuse for concealing the truth, and his failure to immediately inform the police that only Villar stabbed the driver lent a fabricated character to his version. On Whether the aggravating circumstances of nocturnity and abuse of superiority were present: The Supreme Court ruled that neither nocturnity nor abuse of superiority could be appreciated as aggravating circumstances. Regarding nocturnity, the Court found that the prosecution's evidence did not conclusively establish that the perpetrators purposely sought the cover of night to commit the crime with impunity, as Detective Rentoy testified the scene was well-lighted. Citing U.S. vs. Balagtas and Jaime and People vs. Matbagon, the Court stated that nighttime cannot be assumed to have facilitated the commission of the crime. Concerning abuse of superiority, the Court noted the absence of an eyewitness to the actual killing, making it impossible to state with certitude that Repulloso and his companion took advantage of their combined strength. The Court reiterated that numerical superiority does not automatically equate to abuse of superiority and that an aggravating circumstance must be clearly proven, which was not the case here due to insufficient evidence.
Main Doctrine
The admission of a party charged with a crime, deliberately made, is always admissible to show guilt. Corroboration of such admission is not strictly necessary if the admission is direct and pertains to the commission of the crime itself. The testimony of an intimate friend regarding such admission is given weight, especially when the friend is motivated by a desire to tell the truth over close ties of friendship.