People v. Rous
REITERATIONFacts
The Antecedents: Accused-appellants Socrates Rous alias Bobby and Rolando Laygo alias Lando, along with others, were charged with Highway Robbery with Homicide under Presidential Decree No. 532 and violation of the Anti-Carnapping Act of 1972. The victim, Pastor Pasahol, was robbed of jewelry and gold worth P600,000.00 and his Mitsubishi Lancer car worth P210,000.00. During the commission of the robbery, the victim was shot and sustained mortal wounds, leading to his death. The crime was allegedly attended by aggravating circumstances including the use of a motor vehicle, abuse of confidence, superior strength, and treachery. Procedural History: After a joint trial against Laygo and Rous, the Regional Trial Court acquitted Rous of carnapping but found both Rous and Laygo guilty of Highway Robbery with Homicide, sentencing them to reclusion perpetua. The other accused remained at large. The Petition: Both Rolando Laygo and Socrates Rous appealed the decision, primarily assailing the admissibility of their extrajudicial confessions.
Issue(s)
Whether the extrajudicial confessions of accused-appellants Laygo and Rous are admissible in evidence despite their claims of coercion and lack of counsel. Whether the guilt of the accused-appellants for Highway Robbery with Homicide has been proven beyond reasonable doubt based on the admissible evidence.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the extrajudicial confessions of both accused-appellants admissible and upholding their conviction for Highway Robbery with Homicide. The Court sentenced them to reclusion perpetua and ordered them to pay civil indemnity in solidum.
Ratio Decidendi
On the admissibility of extrajudicial confessions: The Court rejected Laygo's argument that his confession (Exhibit C) was inadmissible due to lack of counsel, finding substantial compliance with constitutional requirements as he conferred with Atty. Abraham Datlag, who later reviewed and signed the confession. The presence of relatives also precluded coercion, and Laygo failed to prove violence, intimidation, threat, or promise of reward. The Court applied the same ruling to Rous' confession (Exhibit G), noting that although Atty. Roberto Ferrer was not present during the taking of the confession, Rous signed it upon Atty. Ferrer's advice and in his presence, without coercion, further supported by a medical certificate showing no injuries. Both confessions were deemed admissible. On the sufficiency of evidence for conviction: Based on the admissible extrajudicial confessions of both Laygo and Rous, which corroborated each other and detailed the conspiracy and commission of the crime, the Court found that the prosecution had proven beyond reasonable doubt the guilt of the accused-appellants for Highway Robbery with Homicide. The confessions established the elements of the crime, including the intent to gain, the use of violence and intimidation, the taking of personal property, and the killing of the victim during the commission of the robbery. The Court adopted the factual findings of the trial court, which were supported by the evidence on record, including the details of the robbery, the victim's death, and the subsequent abandonment of the stolen vehicle.
Main Doctrine
Extrajudicial confessions obtained during custodial investigation are admissible in evidence provided that the accused was informed of his right to counsel, and if he opted to have one, he was afforded such assistance, or if counsel was not present during the entire confession, the confession was read and explained to the accused by counsel before signing, and no coercion was employed.