G.R. No. 140514-15 - People vs. Ignas

On the night past midnight of January 23, 1936, the store at No. 1235 Azcarraga Street, Manila, was closed with its inmates asleep.
Faustino Buan, with the assistance of his co-accused Faustino Palac, climbed onto the media agua sheltering the door by standing on Palac’s shoulders.
Buan used this advantage to enter the store through an open window.

Upon entering the store, Buan proceeded downstairs and encountered two Chinese store occupants who had just awakened.
A fight ensued between Buan and the Chinese, during which Buan wounded one of them, identified as Yap Kim Seng.
Following the altercation, Buan escaped by retracing his steps: running upstairs, exiting through the same window, and jumping from the media agua onto the sidewalk.

In the midst of the disturbance, articles and a sum of P44.50 disappeared from the store, linking the criminal act to robbery.
The events of that early morning thus combined elements of robbery with homicide.

During trial, the participation of Faustino Buan and Faustino Palac in the crime was established through their respective confessions recorded on March 3 and 6, 1936, in the presence of police inspector Fidel Zaldana.
Both confessions admitted their roles in entering the store and the subsequent violent encounter that resulted in the death of Yap Kim Seng.

Bruno was charged as a co-accused; however, his involvement was limited to allegedly acting as a guard at the corner of Aguilar and Azcarraga Streets while Buan was entering the store.
The confessions of Buan and Palac, which mentioned Bruno, were used to suggest his tacit consent and participation.
Nonetheless, during the trial, the same accused denied that Bruno had any prior knowledge of their intent to commit the robbery.

Conrado Bruno’s sole evidentiary support came from a statement made on March 2, 1936, in the presence of inspector Zaldana.
His statement recounted his incidental encounter with Buan on Calle Azcarraga and subsequent events during their interaction, without admitting any direct involvement in the crime or showing evidence of a conspiracy.
Additionally, Bruno testified as a witness, providing an account that contradicted the narrative of his active participation in the robbery.

The lower court sentenced all three accused—Buan, Palac, and Bruno—to reclusion perpetua, required them to indemnify the heirs of the deceased in the sum of P1,000, and imposed trial costs.
While Buan and Palac later desisted from their appeal, Bruno alone pursued an appeal challenging his conviction.

Whether the confessions of Faustino Buan and Faustino Palac, which incriminated Conrado Bruno by suggesting his complicity, could be used as evidence against him without independent corroboration.
If the necessary requirement for corroborative evidence was absent, can such statements be reliably used to establish Bruno's participation in the crime?

Whether the evidence, including Bruno’s own statement and the surrounding testimonies, sufficiently demonstrated his direct participation or conspiracy in the commission of the robbery with homicide.
If Bruno’s role was limited to that of a mere bystander or guard, does such involvement rise to the level of criminal complicity warranting a conviction?