Facts:

• The accused-appellant, Jimmy Alberca, was charged with robbery with homicide and physical injuries.
• The crime occurred on April 11, 1994, at the Saycon compound in Quezon City.
• Security guard Felipe Climaco was stabbed multiple times and died; houseboy Joey Rodriguez sustained injuries.
• Alberca was apprehended on April 17, 1994, and gave an extrajudicial confession on April 19, 1994.
• The confession was made in the presence of his wife and a lawyer, Atty. Erlando A. Abrenica, detailing the crime's planning and execution.
• Alberca later claimed his confession was coerced and that he was in San Miguel, Bulacan, at the time of the crime.
• The trial court found him guilty, sentenced him to death, and ordered him to indemnify Climaco's heirs and compensate for the stolen firearm.
• Alberca appealed, arguing the inadmissibility of his confession and the unreliability of the prosecution's evidence.

Issue:

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Ruling:

1. The Supreme Court ruled that the extrajudicial confession was admissible.
2. The Court found the prosecution's evidence sufficient to prove Alberca's guilt beyond reasonable doubt.
3. The death penalty was not imposed due t...(Unlock)

Ratio:

1. The Court held that Alberca's constitutional rights were not violated during the investigation. He was informed of his rights, and his waiver of these rights was made in the presence of his wife and a lawyer. The Court found no credible evidence of coercion or duress. The document containing his confession was signed voluntarily, and the details provided in the confession were consistent and specific, making it improbable that it was fabricated.
2. The defense of alibi was dismissed as Alberca failed to prove that it was physically impossible for him to be at the crime scene. The positive identification by Joey Rodriguez and the circumstantial evidence, including Alberca's presence at the scene and his flight to Bulacan, supported the prosecution's case. T...continue reading