Case Digest (G.R. No. L-30028)
Facts:
The case "The People of the Philippines vs. Cresencio Doble, et al." (G.R. No. L-30028) was decided by the Supreme Court of the Philippines on May 31, 1982. This suit arose from a bank robbery committed in Navotas, Rizal on June 14, 1966, involving multiple fatalities, multiple frustrated homicides, and assaults on law enforcement personnel. Of the ten accused, only five were tried, with the remaining five identified as "John Does" remaining at large. The trial court, the Court of First Instance of Rizal, imposed the death penalty on Cresencio Doble, Antonio Romaquin, and Simeon Doble. Two defendants, Mateo Raga and Celso Aquino, were acquitted. The events of the robbery unfolded when ten armed men, after departing from Manila by a motor banca, aimed to rob the Prudential Bank and Trust Company branch in Navotas. Eight of the criminals disembarked, created havoc by shooting at the bank and among those present, resulting in several deaths and injuries. They r
Case Digest (G.R. No. L-30028)
Facts:
- Overview of the Crime
- A bank robbery was committed in band on the night of June 13–14, 1966, in Navotas, Rizal.
- The crime involved multiple offenses including robbery in band, multiple homicide, multiple frustrated homicide, and assault upon agents of authority.
- Ten men were implicated, though only five were apprehended and tried; the remaining five were identified only as “John Does” and remained at large.
- Sequence of Events
- Late on June 13, 1966, a group of ten heavily armed men left Manila via a motor banca and proceeded to Navotas.
- Eight of these men disembarked and moved toward the Prudential Bank and Trust Company branch located near the beach.
- Gunshots erupted, creating panic among bystanders; during the mayhem, several persons were killed—including law enforcement officers (e.g., Sgt. Alejandro Alcala, Sgt. Eugenio Aguilos, Cpl. Teofilo Evangelista) and a market collector, Dominador Estrella—and others were injured.
- The band later reboarded their banca, with some carrying bayongs, and escaped the scene.
- Details of the Robbery at the Bank
- The targeted branch of the Prudential Bank and Trust Company had unconventional operating hours (open at midnight until 8:00 a.m.) and was staffed by approximately ten employees with a security guard.
- At about 12:30 a.m. on June 14, 1966, two men entered the bank requesting money change; upon refusal due to unavailability of small denominations, three armed men burst in firing at the ceiling and walls and demanding access to the vault.
- After the vault was forced open, the robbers confiscated cash amounting to P10,439.95.
- A police outpost adjacent to the bank recorded the confrontation where Pat. Nicolas Antonio and other officers witnessed the shooting and the subsequent collapse and death of some of their colleagues.
- Involvement of the Accused
- Among the five accused brought to trial were Cresencio Doble, Simeon Doble, and Antonio Romaquin; two others (Mateo Raga and Celso Aquino) were acquitted.
- The trial court initially imposed the death penalty on Cresencio Doble, Simeon Doble, and Antonio Romaquin.
- Evidence showed that a meeting held at Simeon Doble’s house had served as a conference among the malefactors prior to the robbery, yet his physical condition (a 5-year old foot injury) rendered him incapable of active participation in the commission of the crime.
- Extra-Judicial Statements and Evidence
- Extra-judicial statements were obtained from the accused during custodial investigations.
- Cresencio Doble and Antonio Romaquin alleged that their respective statements were extracted under duress, involving physical violence and intimidation.
- Cresencio testified that he was struck and his eyesight became dim, leading him to sign a document he could not read.
- Romaquin gave a similar account of coercion, alleging a gun was pointed at him to force his compliance.
- The statements were cross-examined with other evidence indicating:
- Consistency between the details provided by both appellants, especially regarding the sequence from obtaining a banca to the escape.
- A lack of medical corroboration for the alleged injuries.
- That another co-accused, Celso Aquino, gave a statement without evidence of coercion, thereby undermining the claims of violent extraction.
- A note (Exhibit “H”) was also presented, in which Cresencio Doble requested Romaquin not to reveal the names of their companions, indicating mutual awareness of the criminal grouping.
- Alleged Role of the Accused
- Simeon Doble’s involvement was limited to hosting the meeting where the conspirators planned the robbery; his non-participation was supported by his inability to contribute practically due to his injury.
- Cresencio Doble and Antonio Romaquin were implicated in providing logistical support:
- Cresencio’s role involved procuring a banca and accepting a gun with which he was expected to cover Romaquin to prevent his escape.
- Romaquin’s involvement centered on supplying his banca for transportation and receiving a nominal sum (P41.00) later, suggesting a support role rather than full-fledged participation.
- The extra-judicial statements and corroborative evidence indicated that although they cooperated with the principal malefactors, their participation was not integral to executing the robbery.
Issues:
- Admissibility of Extra-Judicial Statements
- Whether the extra-judicial statements obtained from Cresencio Doble and Antonio Romaquin were admissible in evidence, given the allegations of force, coercion, and violation of constitutional rights (right to counsel and protection against self-incrimination).
- The impact of the absence of medical evidence to corroborate the claims of physical abuse and the alleged testimonies by alleged torturers.
- Extent of the Accused’s Participation
- Whether the participation of the accused—specifically Cresencio Doble and Antonio Romaquin—amounted to being complicit as co-principals or merely as accomplices.
- The significance of Simeon Doble’s mere presence at the meeting (hosted at his house) and whether this implicates him in the planning or execution of the robbery and resultant violence.
- Nature of the Criminal Design
- Whether the accused were involved in a conspiracy that also entailed a criminal design to kill, or if their liability should be confined solely to their assistance in the robbery.
- The implications of the malefactors’ preparedness to use deadly force (as evidenced by the heavy armament) on the liability of the accused.
- Constitutional Concerns
- The relevance of the right to counsel and the protection against self-incrimination under the circumstances of custodial interrogation in 1966 versus the standards set by the 1973 Constitution.
- Whether the absence of the constitutional right during the interrogation should affect the admissibility of voluntary confessions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)