Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Eduardo Elegino y Sorronte, Rodolfo Buenbrazo y Bastasa, and Uldarico Sanchez y Tupaz as the accused. The events transpired on September 14, 1980, in Davao City, Philippines. The Assistant City Fiscal filed an information on January 19, 1981, charging the accused with robbery with homicide under Article 294, Paragraph 1 of the Revised Penal Code. The information alleged that the accused conspired to rob Eliseo Gamonido, the driver of a PU Minica, and during the robbery, they attacked and killed him.

Upon arraignment on February 5, 1981, all accused pleaded "not guilty." Due to incompatible defenses, the trial court appointed separate counsel for each accused. The prosecution later moved to discharge Uldarico Sanchez as a State witness, which the court granted despite opposition from his co-accused. Sanchez testified that after consuming alcohol, the trio took a bus to Davao City, wh...

Facts:

Background of the Case

• The accused, Eduardo Elegino, Rodolfo Buenbrazo, and Uldarico Sanchez, were charged with Robbery with Homicide under Article 294, Paragraph 1 of the Revised Penal Code.
• The crime occurred on September 14, 1980, in Davao City, Philippines.
• The victim, Eliseo Gamonido, was a PU Minica driver who was robbed of P70.00 and subsequently killed.

Events Leading to the Crime

• On September 14, 1980, at around 3:00 PM, Sanchez and Elegino were drinking "tuba" at Buenbrazo's house in Toril, Davao City.
• After consuming alcohol, they decided to go to Davao City to deliver a telegram. They boarded a Mintranco bus and later took a PU Minica driven by Gamonido.
• During the ride, Buenbrazo and Gamonido had a heated altercation. Buenbrazo stopped the cab, got out, and physically assaulted Gamonido, strangling him until he died.
• Sanchez testified that he and Elegino were surprised by Buenbrazo's actions, as there was no prior agreement to assault the driver.

Aftermath of the Crime

• After Gamonido's death, Buenbrazo placed the lifeless body in the rear of the cab and ordered Sanchez to drive the vehicle.
• They returned to Godo's Beach, where Elegino took the victim's wallet and handed it to Buenbrazo, who took the money and discarded the wallet inside the cab.
• The trio then went to Buenbrazo's house, where they continued drinking until their arrest the next morning.

Medical Findings

• Dr. Juan M. Abear, the medico-legal officer, conducted an autopsy and found that the victim died from strangulation and ligature marks on the neck, along with other injuries.

Custodial Investigation

• The accused were apprised of their constitutional rights before giving their extrajudicial confessions. However, Elegino and Buenbrazo later claimed that their confessions were obtained under duress.

Trial Court Decision

• The trial court found Buenbrazo and Elegino guilty of Robbery with Homicide, sentencing them to death. Sanchez was discharged as a State witness.

Issue:

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Ruling:

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Ratio:

1. Admissibility of Extrajudicial Confessions: Elegino's confession was inadmissible because it was obtained without proper legal safeguards, violating his constitutional rights to remain silent and to counsel.
2. Conspiracy Not Proven: There was no clear evidence that Elegino conspired with Buenbrazo to kill Gamonido. Sanchez's testimony indicated that Elegino was surprised by Buenbrazo's actions, and there was no prior agreement to commit the crime.
3. Liability for Theft: Elegino could not be held liable for theft because the evidence showed that Buenbrazo took the money from the victim's wallet, and the wallet was left in the cab. Elegino's involvement in the theft was not sufficiently proven.