People v. Sabban
REITERATIONFacts
1. The Antecedents: The case involves the brutal robbery and homicide of Nancy Maxey and her maid, Nora Mercado. On September 2, 1989, the victims were found dead in their Quezon City residence. Nancy Maxey, an engineer, was found in her bathtub with multiple stab wounds, while Nora Mercado was found strangled with a wire. The residence showed signs of ransacking, with jewelry boxes disturbed and cash and assorted jewelry reported missing, with an estimated value of P250,000.00. 2. Procedural History: The appellant, Eduardo T. Sabban, was charged with Robbery with Homicide along with four other unidentified individuals. The trial court, in a decision dated April 29, 1991, found Sabban guilty beyond reasonable doubt and sentenced him to double reclusion perpetua. The court also ordered him to pay compensatory damages to the heirs of both victims. Sabban appealed this conviction to the Supreme Court. 3. The Petition: The appellant, Eduardo T. Sabban, filed an appeal with the Supreme Court, primarily arguing that the lower court erred in convicting him based on the presented evidence. A key contention was the alleged inadmissibility of his sworn statement, taken during custodial investigation, due to a violation of his constitutional right to be assisted by counsel of his own choice. The defense asserted that the confession was obtained in violation of his rights, while the prosecution presented evidence, including the testimony of the investigating officer and the assisting counsel, to demonstrate that Sabban was properly apprised of his rights and voluntarily executed the statement with legal assistance.
Issue(s)
Whether the trial court erred in convicting the accused-appellant of Robbery with Homicide. Whether the accused-appellant's extrajudicial confession was admissible in evidence, considering the alleged violation of his constitutional rights during custodial investigation.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the accused-appellant guilty beyond reasonable doubt of Robbery with Homicide. The Court ruled that the extrajudicial confession was admissible in evidence. The dispositive portion of the trial court's decision, which was affirmed in toto, sentenced the accused to suffer imprisonment of double reclusion perpetua and to pay damages.
Ratio Decidendi
On the conviction for Robbery with Homicide: The Court found ample evidence to establish beyond reasonable doubt appellant's guilt. The testimony of Cesar Agbayani placed appellant at the scene of the crime. Mildred Valencia corroborated this, identifying appellant pressing the doorbell of the victim's house with four companions. The appellant's own extrajudicial confession, deemed admissible, detailed his participation in the crime, including how he facilitated entry into the house and the subsequent events. The Court considered the totality of the evidence, including the confession and the testimonies of witnesses, to be sufficient for conviction. The appellant's defense that he was coerced by Victor Cordova was not given credence in light of the other evidence presented. On the admissibility of the extrajudicial confession: The Court held that the evidence did not support the appellant's contention of a violation of his constitutional right to counsel. Pat. Rolando Fernandez testified that he apprised appellant of his constitutional rights, including the right to remain silent and the right to counsel. Crucially, appellant gave his statement in the presence of Atty. Justino San Juan of the Integrated Bar of the Philippines (IBP), Quezon City Chapter. Atty. San Juan himself testified that he was present during the investigation, ensured that appellant had no signs of physical harm, and confirmed that appellant understood his rights and was willing to give a statement with him as counsel. The Court emphasized that a lawyer is an officer of the court and enjoys the presumption of regularity in the performance of his duties. Furthermore, the trial court observed that the sworn statement was replete with details only a confessant could have known.
Main Doctrine
An extrajudicial confession, even if taken during custodial investigation, is admissible in evidence if the accused was apprised of his constitutional rights and was assisted by counsel of his own choice, or by a counsel appointed by the court, and the confession was freely and voluntarily given.