Facts:

The case of People of the Philippines vs. Jimmy Alberca arises from an incident that occurred on April 11, 1994, at approximately midnight, at the residential compound of Rebecca Saycon located at No. 99 Tandang Sora Avenue, Quezon City. The accused-appellant, Jimmy Alberca, was charged with Robbery with Homicide and Physical Injuries following a violent confrontation involving him and his accomplices against Felipe Climaco, the security guard, and Joey Rodriguez, a houseboy. During the altercation, Climaco was killed, while Rodriguez sustained injuries.

The prosecution's account established that after entering the compound, the group, including accused-appellant Alberca, attacked Climaco with bladed weapons, resulting in multiple stab wounds that ultimately led to Climaco's death. The attack also involved the attempted robbery of Climaco's service firearm, a .38 caliber revolver. The incident escalated when Rodriguez, who was attacked after them, identified Alberca

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Facts:

Chronology and Incident Details

• On April 11, 1994, in Quezon City at the Saycon compound, the accused-appellant, Jimmy Alberca, along with several accomplices, entered the premises with the intent to commit robbery, homicide, and inflict physical injuries.
• The plan involved a premeditated attack on the residence of Pastor and Rebecca Saycon, where security guard Felipe Climaco and houseboy Joey Rodriguez were present.
• During the incident, Climaco was stabbed multiple times with bladed weapons, sustaining fatal wounds, while Joey Rodriguez was also stabbed but sustained injuries that were treatable.

Testimony and Physical Evidence

• Witness testimony – particularly from Joey Rodriguez – provided details of the sequence of events:
• Joey was awakened by unusual movement and encountered Climaco retrieving a gun before hearing a gunshot.
• He later saw the accused-appellant attacking him and subsequently observed Climaco lying wounded near the swimming pool.
• The autopsy report confirmed multiple stab wounds on Climaco, detailing injuries on the chest, thorax, abdomen, and other parts of the body, establishing the cause of death as due to stabbing.
• Physical evidence included:
• The service revolver (a .38 cal. revolver) found missing from the victim, later seized as evidence.
• Bloodstains along the wall separating the Saycon compound and the accused’s house, linking the accused to the crime scene.

Arrest and Extrajudicial Confession

• Jimmy Alberca was arrested on April 17, 1994, at his residence in San Miguel, Bulacan.
• After his arrest by NBI agents, he was brought to the NBI Headquarters on Taft Avenue in Manila where he gave an extrajudicial confession in the presence of his wife, Noemi Alberca, and counsel, Atty. Erlando A. Abrenica.
• The confession was documented under Exhibit “B” and comprised two parts:
• A waiver of constitutional rights where he was informed in Filipino of his right to remain silent and to have competent and independent counsel.
• A detailed narrative of the events that transpired on April 11, 1994, including the planning and execution of the crime.

Details of the Confession and Waiver of Rights

• The document explicitly stated that the accused was informed of his constitutional rights under Art. III, Sec. 12 of the Constitution.
• Despite later claims of coercion, the confession was signed in the presence of his wife and counsel, and it was reaffirmed before the Assistant City Prosecutor.
• The accused later argued that he was forced to sign the document and that the counsel present was not of his own choosing; however, his signature along with his wife’s executed waiver contested that assertion.

Alibi and Contradictory Testimonies

• The accused maintained an alibi, claiming that he was in San Miguel, Bulacan at the time of the crime, having traveled there on April 10, 1994, to visit an aunt.
• The defense’s alibi was contradicted by:
• Testimony from witnesses such as Joselito Aborque who identified him at his residence with male visitors on April 10, 1994.
• Credible eyewitness identification by Joey Rodriguez who, even though not personally acquainted with him, could reliably place him at the scene due to the proximity of his house to the compound and sufficient lighting.
• Circumstantial evidence – including the accused’s flight to Bulacan after the event – further weakened his alibi claim.

Conspiracy and Group Involvement

• Evidence indicated that the robbery was planned and executed in concert with accomplices including Diego Aruta, Darius Caenghog, Jhonny “Almar” Alcober, Oscar “Lucas” Clariza, and Bengie “Benny” Demson.
• The trial record shows that although the intended robbery of the Saycon residence was not fully consummated, the act of taking the service firearm and the fatal stabbing fell within the ambit of a conspiratorial crime.
• The rule in criminal conspiracy was invoked to hold all members liable for the acts committed by one of them during the execution of the plan.

Circumstantial Corroboration of Guilt

• Detailed aspects of the extrajudicial confession – including specific names, times, and actions – helped establish the sequence of events and the accused’s participation.
• The combination of eyewitness accounts, physical evidence, and the narrative contained in the confession collectively pointed unmistakably to the accused’s presence and involvement in the crime.

Issue:

Admissibility and Voluntariness of the Extrajudicial Confession

• Whether the accused-appellant’s extrajudicial confession should have been declared inadmissible on the ground that it was obtained in violation of his constitutional rights.
• The issue of whether he was properly informed of his right to remain silent and to have access to competent and independent counsel before waiving those rights, despite later claims of being coerced.

Credibility and Weight of Prosecution Versus Defense Evidence

• Whether the trial court erred in giving full credence to the testimonies of prosecution witnesses—particularly Joey Rodriguez—despite the defense’s detailed alibi claim.
• The evidentiary conflict between the positive identification of the accused and the defense evidence presenting his whereabouts in Bulacan at the time of the crime.

Appropriateness of the Conviction and Imposed Penalty

• Whether the elements of robbery with homicide were adequately proven beyond reasonable doubt, given that the robbery was incomplete but homicide was committed during the course of the offense.
• Whether the penalty of death was properly imposed, especially in light of the classification of the group’s conspiracy as either a mere agreement or an organized/syndicated crime group.
• The significance of the aggravating circumstance of nighttime in the commission of the crime and whether it warranted the harsher penalty under the amended provisions of the Revised Penal Code.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)