People v. Page
REITERATIONFacts
The Antecedents: William Page, an eighteen-year-old high school student, was charged with robbery with homicide. According to his confession, he and his friend Crisanto Camposano, armed with a balisong and a revolver respectively, boarded a jeepney. Page sat in the front seat with the driver and a male passenger, while Camposano sat in the back with two female passengers. They held up the driver and passengers, taking their money and jewelry. Page witnessed Camposano dumping the two female passengers out of the moving jeepney on Roxas Boulevard. Page and Camposano then directed the driver to proceed towards the airport, where they alighted near Page's residence. Camposano gave Page a watch and a ring as his share of the loot. One of the female passengers, Veronica Villaverde-Balacapo, died from severe head injuries sustained when she fell from the jeepney. The other female passenger, Cesarean Villaverde, was also pushed out but her survival was unclear. Procedural History: The Court of First Instance of Rizal convicted William Page of robbery with homicide, sentencing him to reclusion perpetua and ordering him to pay indemnity and moral damages to the heirs of Veronica Villaverde-Balacapo. Page appealed the decision. The Petition: Page contended that the trial court erred in relying on his repudiated confession, in convicting him despite not being identified by an eyewitness, and in convicting him based on weak circumstantial evidence.
Issue(s)
Whether the trial court erred in relying on the appellant's confession. Whether the appellant's conviction is valid despite the eyewitness's failure to identify him. Whether the evidence presented sufficiently proved the appellant's guilt beyond reasonable doubt. Whether the appellant is liable for robbery with homicide, considering he did not directly cause the victim's death.
Ruling
The Supreme Court affirmed the decision of the lower court, finding William Page guilty of robbery with homicide, with a modification to include the value of stolen items. The Court held that Page is liable for the special complex crime of robbery with homicide based on conspiracy and his participation in the robbery, even though Camposano directly caused the victim's death. The Court also affirmed the conviction based on Page's voluntary confession, which was corroborated by other evidence.
Ratio Decidendi
On the admissibility and weight of the confession: The Court held that Page's confession was voluntary and admissible. Patrolmen testified to its voluntariness, and Page's failure to complain about alleged maltreatment to the municipal judge or his aunt and lawyer, who visited him, indicated its authenticity. Furthermore, specific details in the confession, such as his address, maternal surname, the time and place of meeting Camposano, the liquor offered by Camposano's father, the route taken, Camposano's origin, and his prior theft charge, corroborated its veracity. These details would not have been disclosed freely unless the confession was genuine. The Court noted that the confession was taken before the new Constitution, making it admissible even if the requisites of Article IV, Section 20 were not strictly observed. On the eyewitness identification: The Court found that the eyewitness, Randolf Scot's, failure to identify Page during the trial was not fatal to the prosecution's case. Scot testified nine months after the incident and could not recall Page's face, only his thick hair. However, Page's confession explicitly admitted his participation in the holdup and described his seating arrangement in the jeepney, which corroborated Scot's testimony regarding the events. The Court emphasized that Page's confession, which admitted his participation, was the crucial evidence, and it was corroborated by the corpus delicti established by Scot's testimony and the necropsy report. On the sufficiency of circumstantial evidence and reasonable doubt: The Court ruled that Page's guilt was proven beyond reasonable doubt. Once his confession was deemed voluntary, his guilt was established. The Court found his alibi to be a fabrication, as it was contradicted by his school records regarding his residence and his physical condition two days before the crime. The Court reiterated that to establish an alibi, the accused must prove they were in another place, making it impossible to have committed the crime, a requirement Page's alibi failed to meet. The Court also noted that even if he resided in Makati, it would not preclude his participation in the crime in Parañaque, given the proximity. On liability for robbery with homicide despite not directly causing death: The Court held that Page was liable for robbery with homicide as a co-conspirator. The evidence showed a conspiracy between Page and Camposano to commit robbery, evidenced by their prior association, their simultaneous boarding of the jeepney, their coordinated actions inside, and their escape together. The Court applied the principle that if a person creates in another an immediate sense of danger, causing that person to attempt an escape and injure themselves, the former is responsible for the resulting injuries. In this case, Veronica's death was a direct consequence of the fear instilled by Camposano during the robbery, leading her to jump from the moving jeepney. The Court cited jurisprudence establishing that all participants in a robbery are guilty of robbery with homicide if the homicide is committed as a consequence or on the occasion of the robbery, unless they endeavored to prevent the homicide. Page's presence and participation in the robbery emboldened Camposano, making him equally responsible for the homicide.
Main Doctrine
Conspiracy to commit robbery, coupled with the commission of homicide as a consequence or on the occasion of the robbery, makes all conspirators liable for the special complex crime of robbery with homicide, even if they did not directly participate in the killing. The perpetrator of the robbery is also responsible for the homicide if the victim's death resulted from an act done in immediate fear of the robber, leading the victim to attempt an escape.