People v. Gonzales
REITERATIONFacts
The Antecedents: Pantaleon Gonzalez, Patricio Mercado, Telesforo Fuego, and Mariano Arguelles were charged with robbery. The information alleged that on the night of September 20, 1930, in Paniqui, Tarlac, the accused, acting in concert and pursuant to a previous agreement, unlawfully entered an inhabited house belonging to Maria Arroyo through a window, broke open a closed box, and took possession of a basket containing money, jewelry, and valuable papers valued at P15,777.50. Procedural History: The Court of First Instance of Tarlac tried the case against Mercado, Fuego, and Arguelles (Gonzalez demanded a separate trial). The court found them guilty of robbery with the aggravating circumstance of nocturnity, sentencing each to six years and one day of presidio mayor, with accessories, and to jointly and severally indemnify the offended party in the sum of P15,882.50, plus costs. These defendants appealed. The Petition: The appellants assigned errors concerning the admissibility of their confessions, alleging they were obtained by force, violence, duress, intimidation, and fraud, and that the court erred in not giving credence to their testimonies and in finding them guilty.
Issue(s)
Whether the confessions of the accused, Exhibits A, B, and C, were obtained by means of force, violence, duress, intimidation, and fraud, rendering them inadmissible. Whether the court erred in finding the accused Mercado, Fuego, and Arguelles guilty of the crime charged. Whether the aggravating circumstance of nocturnity was correctly appreciated. Whether the indemnity awarded to the offended party was correctly calculated.
Ruling
The judgment of the Court of First Instance is affirmed with a modification regarding the indemnity. The appellants are found guilty of robbery with the aggravating circumstance of nocturnity.
Ratio Decidendi
On the admissibility of confessions: The Court found no evidence to support the appellants' contention that their confessions (Exhibits A, B, and C) were extorted through force, violence, duress, intimidation, or fraud. The confessions were made before the justice of the peace and witnesses in the absence of the Constabulary officers involved in the investigation, a precaution taken in obedience to instructions from the judge of the Court of First Instance. The record did not contain anything to substantiate the defense's insinuation of maltreatment. Therefore, the confessions were deemed admissible and established the appellants' guilt beyond reasonable doubt. On the guilt of the accused: Based on the admissible confessions and the evidence presented, the Court was convinced that the appellants' guilt for the crime of robbery was established beyond all reasonable doubt. Mariano Arguelles admitted his participation at the invitation of Pantaleon Gonzalez, stating Gonzalez and Patricio Mercado entered the house, and he saw them carrying a basket upon their exit. Patricio Mercado confessed to climbing through the window with Pantaleon Gonzalez and carrying away the basket. Telesforo Fuego confessed to remaining on the street as a lookout while Gonzalez and Mercado came down with the basket and bank notes. On the aggravating circumstance of nocturnity: The Court affirmed the appreciation of nocturnity as an aggravating circumstance. The crime was committed during the night of September 20, 1930, and the offenders took advantage of the darkness to perpetrate the robbery, as evidenced by the fact that the offended party only noticed the cut wire on the box when she was about to open it, and the subsequent disappearance of her valuables. The Penal Code provides that when the crime is accompanied by the aggravating circumstance of nocturnity, the penalty must be applied in its maximum degree. On the calculation of indemnity: The Court accepted the Attorney-General's recommendation to deduct the value of the insurance policy from the total indemnity, as the offended party had not lost its value but could obtain another copy. The value of the stolen receipts was considered a real pecuniary loss, but any amount the offended party might collect from her debtors based on these receipts would be deducted from the indemnity. Consequently, the civil liability was reduced from P15,882.50 to P10,382.50.
Main Doctrine
Confessions obtained before a justice of the peace, in the absence of constabulary officers, and without evidence of maltreatment, are admissible in evidence. The aggravating circumstance of nocturnity may be considered when the crime is committed at night and the offenders took advantage of the darkness.