People v. Alvarez
REITERATIONFacts
The Antecedents: On June 3, 1997, a dead body, identified as Danilo Hernandez, was found inside a taxicab in Quezon City. The victim sustained a gunshot wound to the nape. Recovered from the taxicab were personal effects including a caliber .45 pistol, a gold ring with a diamond stone, a citizen watch, and an address book, which were subsequently identified as stolen from the victim. In a separate incident on June 15, 1997, Salvador Dizon carnapped a taxicab and its driver. Dizon was killed in a shootout with police on June 17, 1997, and a .38 caliber revolver was recovered from him. Ballistic examination revealed that the bullet recovered from Hernandez's body was fired from this same revolver. Procedural History: The appellant, Jacinto Alvarez Jr., was charged with robbery with homicide. The prosecution presented an extra-judicial confession made by Alvarez, wherein he admitted to conspiring with Salvador Dizon in robbing and killing the victim. Alvarez claimed the confession was obtained through torture and intimidation and was made in the absence of counsel. The Regional Trial Court of Quezon City, Branch 81, found Alvarez guilty beyond reasonable doubt of robbery with homicide and sentenced him to reclusion perpetua, ordering him to indemnify the heirs of the victim. The RTC decision was based significantly on Alvarez's extra-judicial confession. The Petition: Alvarez appealed his conviction, arguing that his extra-judicial confession was inadmissible due to coercion and that some statements were not his own. He contended that the trial court erred in convicting him based on this confession and in not acquitting him on grounds of reasonable doubt.
Issue(s)
Whether the extra-judicial confession of the appellant was admissible in evidence. Whether the appellant is guilty beyond reasonable doubt of the crime of robbery with homicide.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the appellant guilty of robbery with homicide. The Court sentenced him to suffer the penalty of reclusion perpetua and ordered him to indemnify the heirs of the victim in the amount of P50,000.00 as civil indemnity and P50,000.00 as moral damages.
Ratio Decidendi
On the admissibility of the extra-judicial confession: The Court held that the extra-judicial confession of the appellant was admissible in evidence. The Court found that Alvarez failed to present any evidence to prove he was tortured or intimidated, such as physical marks or complaints to authorities or his lawyer. The Court reiterated the presumption that extra-judicial confessions are voluntary, and in the absence of conclusive evidence of vitiated consent, such confessions will be sustained. Furthermore, the Court noted that the confession was corroborated by the testimonies of police officers and contained details that only the appellant could have known, including their modus operandi and the location of the stolen items. The presence of lawyers, reporters, and his relatives during the taking of the confession also belied claims of coercion. The Court also found that the appellant's claim of not having counsel of his choice was unsubstantiated, as his own testimony indicated he selected Atty. Orlando Salatandre Jr. as his counsel. On the guilt of the appellant for robbery with homicide: The Court found sufficient evidence to convict the appellant of robbery with homicide. The appellant's extra-judicial confession, deemed admissible, detailed the conspiracy with Salvador Dizon, the commission of the robbery by means of force and intimidation (shooting the victim), the death of the victim as a direct consequence thereof, and the subsequent taking of personal properties. The corroboration from the ballistic report linking the recovered firearm to the victim's death, and the recovery of stolen items based on the confession, further strengthened the prosecution's case. The Court applied Article 294, paragraph 1 of the Revised Penal Code, which penalizes robbery with homicide with reclusion perpetua to death. Since no aggravating or mitigating circumstances were present, the lesser indivisible penalty of reclusion perpetua was correctly imposed.
Main Doctrine
An extrajudicial confession is presumed voluntary and admissible in evidence unless there is conclusive proof that the declarant's consent was vitiated. The confession's voluntariness can be inferred from its detailed nature, corroboration by other evidence, and the absence of physical marks or complaints of maltreatment.