People v. Llenaresas
REITERATIONFacts
The Antecedents: Romeo Jabil, Armando Depusoy, Rufo Llenaresas, Jesus Capistrano, Herminio de Ramos, and Rolly Hernandez were charged with robbery with homicide. The information alleged that on January 31, 1988, in Lucena City, the accused, armed with deadly weapons and acting in conspiracy, robbed Antonio Maligaya of a passenger jeepney, cash, and jewelry valued at P101,000.00. During the course of the robbery, they stabbed and killed Maligaya. Procedural History: At arraignment, Romeo Jabil, Armando Depusoy, and Rufo Llenaresas pleaded not guilty. The other three accused remained at large. Romeo Jabil escaped during the trial and remained at large. The trial proceeded against Armando Depusoy and Rufo Llenaresas, and also against Romeo Jabil in absentia. On May 15, 1991, the trial court convicted Romeo Jabil and Rufo Llenaresas of robbery with homicide, sentencing them to reclusion perpetua and ordering them to pay civil indemnity and expenses. Armando Depusoy was acquitted. Rufo Llenaresas is the sole appellant. The Petition: Appellant Rufo Llenaresas assigns two errors: (1) the trial court erred in admitting his extra-judicial confession as it was obtained in violation of the Constitution, and (2) the trial court erred in finding him guilty beyond reasonable doubt. The principal issue raised is the admissibility of his extra-judicial confession, which he claims was extracted through coercion, force, and intimidation without the assistance of counsel. He asserts he was not informed of his constitutional rights during custodial investigation and that he was beaten into signing the confession. The prosecution presented evidence, including the confession itself and testimonies of police officers and a prosecutor, to counter these claims, asserting that Llenaresas was informed of his rights, voluntarily confessed, and was assisted by counsel.
Issue(s)
Whether the extra-judicial confession of appellant Rufo Llenaresas is admissible in evidence. Whether the prosecution proved the guilt of appellant Rufo Llenaresas beyond reasonable doubt for the crime of robbery with homicide.
Ruling
The judgment of conviction rendered by the trial court is AFFIRMED, with the indemnity for the death of Antonio Maligaya increased to P50,000.00.
Ratio Decidendi
On the admissibility of the extra-judicial confession: The Court affirmed the trial court's decision to admit the extra-judicial confession of appellant Rufo Llenaresas. The confession itself stated that Llenaresas was informed of his right to remain silent and his right to counsel, and that he voluntarily waived these rights. The confession also indicated that he was assisted by Atty. Meliton Angeles. This was corroborated by the testimony of Cpl. Ernesto Ginauli, who took the statement, and Second Assistant City Prosecutor Pedro S. Nantes. Prosecutor Nantes testified that he personally examined Llenaresas, confirmed he understood his rights, was not coerced, and voluntarily executed the statement. He even called Atty. Angeles, who confirmed his assistance. The Court found that Llenaresas's claims of coercion and intimidation were unsubstantiated by any medical or physical evidence, and he failed to complain to Prosecutor Nantes or anyone else about the alleged beatings. The detailed nature of the confessions, which corroborated each other, also lent them the ring of truth, making it difficult to believe they were fabricated by the police. Therefore, the confession was deemed admissible. On the guilt of the appellant beyond reasonable doubt: The Court found that the prosecution sufficiently proved the guilt of appellant Rufo Llenaresas beyond reasonable doubt. The extra-judicial confession, which was admitted into evidence, detailed his participation in the robbery with homicide, including stabbing the victim multiple times. This confession was corroborated by other evidence, such as the personal belongings found at the scene and the recovery of the stolen jeepney. The trial court, having heard the testimonies of the witnesses, including the appellant and the police officers, chose to believe the latter, a determination that the appellate court found no sufficient basis to overturn. The Court reiterated that the warrantless arrest, even if irregular, did not invalidate the subsequent trial and conviction once a valid information was filed and the proceedings commenced. Thus, based on the admissible confession and corroborating evidence, the guilt of the appellant was established.
Main Doctrine
An extra-judicial confession, even if obtained during custodial investigation, is admissible if the accused was informed of his constitutional rights, voluntarily executed the confession, and was assisted by counsel, as evidenced by the confession itself and corroborating testimonies. A warrantless arrest, while potentially irregular, does not invalidate subsequent proceedings once a valid information has been filed and trial has commenced.