Case Digest (G.R. No. 129211)
Facts:
People of the Philippines v. Wilfredo Rodriguez y Culo and Larry Artellero y Rico, G.R. No. 129211, October 02, 2000, Supreme Court Second Division, Quisumbing, J., writing for the Court.The prosecution charged Wilfredo Rodriguez y Culo and Larry Artellero y Rico with Robbery with Homicide for the October 11, 1991 killing of bank security guard Ramon Matias at the Far East Bank and Trust Company, Blumentritt branch, Manila. The Regional Trial Court (Manila, Branch 29) found both defendants guilty not of robbery with homicide but of murder and sentenced each to reclusion perpetua with P50,000 civil indemnity; only Artellero pursued an appeal to the Supreme Court. Rodriguez withdrew his appeal for financial reasons, but the Court considered his conviction as well because the cases were factually linked.
On discovery the victim’s body was hogtied with 32 stab wounds; the bank showed signs of forced entry and three .38 revolvers and five 12-gauge shotguns were reported missing. Police located Artellero and Rodriguez at the construction site above the bank on the afternoon of October 11, 1991, seized a pair of maong pants and a shirt with reddish stains, and arrested both. Rodriguez executed an extrajudicial confession on October 15, 1991; he was assisted by Atty. Procopio Lao III of the Public Attorney’s Office only minutes before signing. The NBI chemistry supervisor testified that stains on Rodriguez’s clothing tested positive for human blood type O; the victim’s blood type was not established for comparison.
At trial the prosecution introduced the confession, physical exhibits (including the maong pants and shirt), the necropsy report (cause of death: multiple stab wounds), police reports, and NBI laboratory results. The defense denied participation, claimed Rodriguez’s confession was coerced, and questioned chain of custody and ownership of the seized clothing. The trial court denied a demurrer to evidence and convicted both accused of murder. On appeal, Artellero raised four assignments of error (chiefly the use of Rodriguez’s extrajudicial confession against him, the probative value of the bloodstained pants, and reliance on cohabitation/work together as proof of conspiracy). The Office of the Solicitor General filed a Manifestation and Motion in Lieu of Appellee’s Brief arguing that Rodriguez’s confession was inadmissible and, even if admissible, the evidence did not prove appellant’s guilt.
The case reached the Court by appeal (Rule 45 petition from the RTC decision). The Second Divisi...(Pro-only)
Issues:
- Was the extrajudicial confession of Wilfredo Rodriguez admissible against himself and against co-accused Larry Artellero?
- Did the remaining evidence, aside from Rodriguez’s extrajudicial confession, establish appellant Artellero’s guilt beyond reasonable doubt (including whether the bloodstained maong pants had probative value)?
- Was the trial court justified in convicting the accused of murder where the Information charged Robbery with Homicide and did not allege the ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)