People v. Robles
REITERATIONFacts
The Antecedents: On January 30, 1987, at around 1:00 P.M., Patrolmen Rey Cocson, Edgar Amurao, and C. Tabanera were on patrol when they flagged down a taxicab due to the suspicious behavior of its passengers. The passengers were identified as Antonio Manas and appellant Oscar Robles. Upon inquiry, Robles admitted that they had robbed the house of Jose Macalino in Makati. A search of the taxicab yielded bags containing stolen items and firearms (a .38 caliber revolver from Robles and a fan knife from Manas). The police contacted Beth M. Puzon, daughter of Jose Macalino, and subsequently turned over Robles and Manas to the Makati Police Department. Detective Ernesto Gatpayat of the Makati Police Station found Jose Macalino's house ransacked and discovered two dead persons inside, identified as Marilou Dalugdugan and Diego Limato, household helpers of Macalino. A screwdriver was found near the body of Dalugdugan. Procedural History: After being apprised of their constitutional rights and in the presence of counsel, Patrolman Celso Noriega took down the statements of Robles and Manas. Robles admitted participation in the robbery but denied involvement in the killings, claiming he was a lookout while Manas and Vicente Antonio entered the house. Manas admitted stabbing Dalugdugan to prevent her from screaming while Antonio stabbed Limato. Manas claimed Robles was inside the house. An Information for Robbery with Double Homicide was filed against Manas, Robles, and Antonio. During pre-trial, the parties stipulated on the facts and genuineness of post-mortem examinations, the existence and value of stolen articles, and the existence of the sworn statements of Robles and Manas, though the truth of their contents was denied on grounds of alleged intimidation. The defense agreed that the prosecution need not present the medical examiner and Jose Macalino, except for a letter from Manas. The prosecution presented Det. Gatpayat, Forensic Chemist Aida Pascual, Patrolman Rey Cocson, and Patrolman Celso Noriega, Jr. Robles and Manas testified, with Robles denying participation and claiming coercion. The RTC convicted both Robles and Manas of Robbery with Homicide, sentencing them to reclusion perpetua and ordering them to pay indemnity. Manas did not appeal. The Petition: Appellant Oscar Robles y Moana appealed his conviction, contending that the trial court erred in convicting him based on inadmissible confessions and insufficient circumstantial evidence.
Issue(s)
Whether the extrajudicial confessions of appellant and his co-accused are admissible in evidence. Whether the circumstantial evidence presented is sufficient to convict appellant beyond reasonable doubt of the crime of Robbery with Homicide. Whether the penalty and indemnity imposed by the trial court are proper.
Ruling
The Supreme Court affirmed the conviction of Oscar Robles y Moana for Robbery with Homicide, with modifications as to the amount of indemnity and the award of exemplary damages. The penalty of reclusion perpetua was affirmed.
Ratio Decidendi
On the admissibility of extrajudicial confessions: The Court held that the extrajudicial confessions of appellant and his co-accused are admissible. The allegation that they were not assisted by counsel during custodial investigation was belied by the records, which clearly showed that Atty. Eugenio C. Macababayao Jr. was present and assisted them throughout the investigation and trial. The lawyer did not dispute his presence or assistance, nor did he deny his signatures attesting to this fact. Furthermore, the pre-trial stipulation explicitly stated that Atty. Macababayao assisted the accused in giving their statements. The Court also noted that appellant never brought to the attention of his counsel that he was threatened, and co-accused Manas even corrected details in his statement, indicating voluntariness. The Court further ruled that any objection regarding the validity of the arrest was deemed waived by appellant's voluntary submission to the trial court's jurisdiction through his plea and active participation in the trial without raising such defects. On the sufficiency of circumstantial evidence: The Court held that there is sufficient evidence to convict appellant beyond reasonable doubt. Citing Section 4 of Rule 133 of the Rules of Court, the Court stated 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 circumstances produces conviction beyond reasonable doubt. In this case, the circumstances proving appellant's culpability were: (1) he planned the robbery with his co-accused; (2) he acted as a lookout; (3) he participated in looting the house after the victims were killed; and (4) he left the house with his co-accused carrying the proceeds of the robbery. The Court reiterated the rule that unexplained possession of stolen articles raises a presumption of robbery when violence or intimidation is involved. The elements of robbery with homicide were established: taking of personal property by violence or intimidation, property belonging to another, intent to gain, and homicide committed on the occasion of the robbery. The Court emphasized that all principals in the robbery are guilty of the special complex crime of robbery with homicide, even if they did not directly participate in the killing, unless they endeavored to prevent it. Appellant's established participation in the looting during the robbery, where the killings occurred, sufficiently proved his culpability for the complex crime. On the penalty and indemnity: The Court affirmed the penalty of reclusion perpetua imposed by the trial court, noting that at the time of the offense, the penalty for robbery with homicide was reclusion perpetua to death, and the subsequent suspension of the death penalty by the 1987 Constitution made reclusion perpetua the proper penalty. However, pursuant to existing jurisprudence, the Court increased the indemnity for the death of each victim to P50,000.00. Additionally, the presence of the second killing was considered an aggravating circumstance, justifying the award of exemplary damages in the amount of P10,000.00 to the heirs of each victim, pursuant to Article 2230 of the New Civil Code. All recovered items were duly restituted to the owners.
Main Doctrine
Extrajudicial confessions are admissible if made with the assistance of counsel, and circumstantial evidence is sufficient for conviction if it meets the required number of circumstances, proven facts, and produces conviction beyond reasonable doubt. In robbery with homicide, all principals in the robbery are guilty of the special complex crime, even if they did not directly participate in the killing.