People v. Doro
REITERATIONFacts
The Antecedents: Around midnight of May 2, 1989, a watchman at Paredes Furniture Store was attacked by three men. Responding policemen found the security guard, Rex Ramos, bleeding from stab wounds. Ramos pointed towards Padre Pio Street, indicating his assailants. While Ramos was taken to the hospital, the policemen pursued the suspects. A shootout ensued, resulting in the death of one suspect, Renato Borja. The other two, accused-appellants Ricky Andag and Oscar Doro, were apprehended. The security guard, Rex Ramos, died of multiple stab wounds, and his issued .38 caliber revolver was stolen and later found near Borja's body. Procedural History: An information for Robbery with Homicide was filed against Oscar Doro, Ricky Andag, and Renato Borja, later amended to exclude the deceased Borja. The accused-appellants pleaded not guilty. At pre-trial, they admitted executing extrajudicial confessions but claimed they were given under duress. The prosecution presented police officers and other witnesses to refute this claim. During the trial, Ricky Andag escaped from confinement, but the trial proceeded against both accused-appellants. The Petition: The accused-appellants appealed their conviction by the Regional Trial Court of Cavite City, Branch 16, for Robbery with Homicide, with each sentenced to suffer the penalty of reclusion perpetua. Their appeal raised issues regarding the sufficiency of circumstantial evidence and the admissibility of their extrajudicial confessions.
Issue(s)
Whether the circumstantial evidence presented was sufficient to convict the accused-appellants beyond reasonable doubt. Whether the extrajudicial confessions of the accused-appellants were admissible as evidence, considering their claim of involuntariness.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellants Oscar Doro and Ricky Andag guilty beyond reasonable doubt of the crime of Robbery with Homicide. Each was sentenced to suffer the penalty of reclusion perpetua. The Court found the appeal to be without merit.
Ratio Decidendi
On the sufficiency of circumstantial evidence: The Court held that circumstantial evidence is sufficient for conviction if there is more than one circumstance, the facts from which inferences are derived are proven, and the combination of all circumstances produces conviction beyond reasonable doubt. In this case, the Court found these elements present. The undisputed facts established that the accused-appellants were seen in the direction pointed to by the victim shortly after the crime, they fled upon seeing the police, their clothes and weapons were bloodstained, and they gave sworn statements admitting to stabbing the security guard to rob him of his revolver. The Court concluded that the combination of these circumstances produced a conviction beyond reasonable doubt for Robbery with Homicide. On the admissibility of extrajudicial confessions: The Court found the accused-appellants' claim that their extrajudicial confessions were obtained through force or intimidation to be improbable. The Court noted inconsistencies in Oscar Doro's testimony regarding the alleged mauling and injuries, particularly his admission that some parts of his confession were true and voluntarily given. The testimony of the defense witness, Dr. Danilo Borbon, also did not fully corroborate the claims of severe maltreatment, as he could not recall the probable cause of the injuries and noted that abrasions and contusions could result from various incidents, including climbing a fence as admitted by Doro. The Court reiterated that the sworn statements of the accused, corroborated by the testimonies of arresting officers who have no motive to falsely testify, are worthy of credit. The Court also noted Ricky Andag's flight from confinement as further evidence against him.
Main Doctrine
Circumstantial evidence is sufficient for conviction if there is more than one circumstance, the facts from which inferences are derived are proven, and the combination of all circumstances produces conviction beyond reasonable doubt. Extrajudicial confessions, even if claimed to be involuntary, are admissible and credible if corroborated by other evidence and if the accused's claims of duress are improbable or unsubstantiated.