People v. De la Cruz
REITERATIONFacts
The Antecedents: Rufino de la Cruz appealed his conviction for robo con homicidio by the Court of First Instance of Bulacan. The victim, Celso Manahan, a nineteen-year-old tricycle driver, was found stabbed to death in an uninhabited place. His tricycle was missing. The sidecar was found later, and the motorcycle was recovered from the house of the accused's relative. The accused surrendered to the police. Procedural History: A complaint for robbery with homicide was filed against Rufino de la Cruz. After a preliminary investigation, an information was filed in the Court of First Instance. The trial court convicted the accused and sentenced him to life imprisonment and to indemnify the heirs of the victim. The Petition: The accused appealed his conviction, arguing that the trial court erred in rejecting his plea of self-defense.
Issue(s)
Whether the trial court erred in convicting the appellant of robbery with homicide. Whether the trial court erred in rejecting the appellant's plea of self-defense.
Ruling
The Supreme Court affirmed the lower court's judgment with the modification that the penalty of life imprisonment should be denominated reclusion perpetua. The Court held that the appellant's extrajudicial confession, corroborated by evidence of the corpus delicti, was sufficient for conviction. The plea of self-defense was rejected due to inconsistencies with the confession and the surrounding circumstances.
Ratio Decidendi
On the conviction for robbery with homicide: The Court found that the corpus delicti was not in question, as the commission of robbery with homicide was established. The case was simplified by the extrajudicial confession of the accused, Rufino de la Cruz, which was never questioned as to its voluntariness or due execution. This confession was corroborated by evidence, including the recovery of the stolen tricycle's motorcycle and sidecar, and the testimony of witnesses who saw the accused driving the victim's tricycle. The Court cited Section 3, Rule 133 of the Rules of Court, stating that an extrajudicial confession corroborated by evidence of the corpus delicti is a sufficient ground for conviction. The appellant's culpability was established beyond reasonable doubt. On the rejection of the plea of self-defense: The Court rejected the plea of self-defense primarily because the appellant did not include any mention of acting in self-defense in his extrajudicial confession. If he had indeed acted in self-defense, this crucial circumstance would have been included in his confession. Furthermore, had he acted in self-defense, he should have reported the incident to the police immediately after fleeing the scene, rather than seeking sanctuary in his relatives' house and attempting to conceal the robbery by selling the stolen motorcycle. The Court also noted inconsistencies between the appellant's testimony and the autopsy report, such as the number of stab wounds and the absence of injuries indicating he was bludgeoned with an iron bar. The Court found it highly improbable that the victim, who had a physical defect and was younger, would have initiated unlawful aggression against the physically superior appellant. The supposed witness, Francisco Sakay, turned out to be a fictitious person, further undermining the self-defense claim.
Main Doctrine
An extrajudicial confession corroborated by evidence of the corpus delicti is sufficient ground for conviction for robbery with homicide. The plea of self-defense is rejected when the accused failed to mention it in his confession and his subsequent actions, such as fleeing and attempting to sell the stolen property, are inconsistent with such a claim.