People v. Nabaluna
REITERATIONFacts
The Antecedents: Accused-appellants Juan Nabaluna and Edgardo Empuerto were found guilty beyond reasonable doubt of Robbery with Homicide by the Circuit Criminal Court of Cebu City and sentenced to death. The Information alleged that the accused, conspiring and confederating, forcibly opened a wooden bank owned by Nazario Bendanillo, taking P200.00, and on the occasion of the robbery, treacherously attacked and killed Bendanillo with a sharp-bladed instrument, causing fatal hemorrhage. Procedural History: The trial proceeded against Nabaluna and Empuerto as their co-accused, Arcadio Lacaron, was at large. The trial court rendered a decision finding them guilty and imposing the death penalty. The Petition: The accused-appellants appealed the decision, raising issues regarding the admissibility of their extrajudicial statements, the sufficiency of evidence, the existence of conspiracy, and the appreciation of aggravating circumstances.
Issue(s)
Whether the extrajudicial statements of the appellants were admissible in evidence. Whether the guilt of the appellants was proven beyond reasonable doubt, and whether conspiracy was sufficiently established. Whether the aggravating circumstances of treachery, abuse of superior strength, and disregard of old age were attendant. Whether the penalty of death was proper.
Ruling
The decision convicting the appellants of Robbery with Homicide is affirmed, but the penalty is modified. The appellants are sentenced to suffer the penalty of reclusion perpetua. They are ordered to jointly and severally indemnify the heirs of the deceased Nazario Bendanillo in the amount of P30,000.00, return P200.00, and pay proportionate costs.
Ratio Decidendi
On the admissibility of extrajudicial statements: The Court held that while the appellants claimed their extrajudicial statements were obtained in violation of their constitutional rights, the records showed they were informed of their rights. Specifically, appellant Juan Nabaluna was informed of his rights and even offered assistance from the Citizens' Legal Assistance Office (CLAO), which he waived. Appellant Edgardo Empuerto also acknowledged being informed of his rights. The Court noted that the guidelines regarding the presence of counsel during waiver, as laid down in later cases like Morales v. Ponce Enrile, were not yet promulgated at the time of the trial court's judgment, thus, the admission of the statements was not erroneous based on the prevailing standards then. Even if the statements were excluded, the Court found sufficient independent evidence to support the conviction. On the sufficiency of evidence and conspiracy: The Court found that even without the extrajudicial statements, the testimonial and circumstantial evidence were sufficient to establish guilt beyond reasonable doubt. The appellants' presence at the scene of the crime, their hasty departure together after the incident, and the testimony of Martin Linihan, who saw Nabaluna jump from the window and Lacaron emerge with a blood-stained knife while Empuerto acted as a lookout, all pointed to their participation. The Court concluded that their conduct before, during, and after the commission of the crime sufficiently reflected the conspiracy that bound them together in the commission of the offense. On the aggravating circumstances: The Court disagreed with the trial court's appreciation of treachery, abuse of superior strength, and disregard of old age. There was no eyewitness to the commission of the crime, and thus no evidence on the method of attack or the victim's awareness, precluding treachery. The mere fact that two accused were armed did not automatically constitute abuse of superior strength; it required a showing of purposely using excessive force disproportionate to the victim's means of defense. Furthermore, disregard of old age is not proper in crimes against property, and robbery with homicide is primarily a crime against property, with homicide being incidental. On the penalty: Given that the aggravating circumstances were not properly appreciated, and considering the penalty for robbery with homicide under Article 294 of the Revised Penal Code ranges from reclusion perpetua to death, the Court modified the penalty from death to reclusion perpetua. The Court found no aggravating circumstances that could rightfully be applied against the appellants, thus warranting the imposition of the lower penalty within the prescribed range.
Main Doctrine
While extrajudicial confessions obtained in violation of constitutional rights are inadmissible, conviction may still stand if supported by sufficient independent evidence, such as circumstantial evidence establishing conspiracy and participation in the crime.