People v. Maneng
REITERATIONFacts
The Antecedents: On March 16, 1993, at approximately 5:15 p.m., a robbery and homicide occurred at the residence of Alfredo Gelito. The housekeepers, Hermosa Gelito and Nenita Santiago, were found dead. Missing items included cash amounting to P45,000.00, assorted jewelries, a radio, a camera, tools, and P5,000.00 belonging to one of the deceased housekeepers. The accused, Joseph Maneng y Ortesa, was apprehended on March 18, 1993, at the Batangas City port, carrying a lady's bag, and was found to possess a necklace with a heart-shaped pendant. He subsequently executed a sworn statement admitting his participation in the crime, after being apprised of his constitutional rights by SPO1 Arnold Alabastro and his counsel de oficio, Atty. Hortensio G. Domingo, Jr. Procedural History: The accused pleaded not guilty to the information charging robbery with double homicide. The Regional Trial Court of Valenzuela, Branch 172, Metro Manila, convicted Joseph Maneng y Ortesa of the complex crime of robbery with homicide and sentenced him to reclusion perpetua, with indemnification to the heirs of the victims. The accused appealed the decision. The Petition: The accused-appellant claimed that the trial court erred in relying on his confession, which he alleged was obtained in violation of his constitutional rights, and in disregarding his alibi.
Issue(s)
Whether the extrajudicial confession of the accused-appellant is admissible in evidence. Whether the defense of alibi is sufficient to overcome the extrajudicial confession. Whether the elements of the crime of robbery with homicide are present. Whether the penalty imposed by the trial court is correct.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, with a modification regarding exemplary damages. The conviction of the accused-appellant for robbery with homicide was sustained.
Ratio Decidendi
On the admissibility of the extrajudicial confession: The Court found the extrajudicial confession of the accused-appellant to be admissible in evidence. It was established that the confession was voluntary and made with the assistance of a competent and independent counsel, Atty. Hortensio G. Domingo, Jr. The confession contained detailed information about the commission of the crime, which only the perpetrator could have known, indicating its voluntariness. The Court reiterated that extrajudicial confessions are presumed voluntary, and in the absence of conclusive evidence of vitiated consent, such confessions will be sustained. The presence of counsel during the taking of the statement, even if appointed by the court or engaged by someone on behalf of the accused, satisfies the constitutional requirement. On the defense of alibi: The Court held that the defense of alibi must fail against a valid extrajudicial confession. Alibi is considered a weak defense, especially when confronted with a confession that contains details only the perpetrator would know. The Court found no evidence of torture, force, violence, threat, or intimidation used against the accused to compel his confession. Therefore, the alibi presented by the accused was disregarded. On the elements of robbery with homicide: The Court found that all the essential elements of robbery with homicide were present. Personal property belonging to the Gelito household was taken by the accused and his companions through violence and intimidation. On the occasion of this robbery, two housekeepers were killed. The Court clarified that the homicide does not need to occur after the robbery; it is sufficient that there is a direct and intimate connection between the robbery and the killing, whether the homicide precedes or follows the robbery. On the penalty and damages: The Court agreed with the trial court that the proper imposable penalty is reclusion perpetua, as the crime was committed before the enactment of Republic Act No. 7659, which reimposed the death penalty. In addition to the death indemnity awarded to the heirs of the victims, the Court awarded P10,000.00 as exemplary damages for each victim, citing the presence of an aggravating circumstance (the second killing) and Article 2230 of the Civil Code. The decision of the trial court was affirmed with this modification.
Main Doctrine
An extrajudicial confession, if found to be voluntary and made with the assistance of counsel, is admissible in evidence and can sustain a conviction, even against a defense of alibi. The elements of robbery with homicide are present when personal property is taken by means of violence or intimidation, and on the occasion thereof, a person is killed.