Case Digest (G.R. No. L-11647)
Facts:
The consolidated cases of *People of the Philippines vs. Juan Escober y Geralde, et al.* stem from a decision made by Judge Oscar Leviste of the Regional Trial Court of Quezon City. The case, Criminal Case No. Q-22896, involved the accused-appellants Juan Escober y Geralde and Macario Punzalan, Jr. y Guevarra, who were found guilty of robbery with homicide and sentenced to death on January 10, 1984. The incident in question occurred on December 3, 1982, when Vicente Chua, his wife Lina, and their two children, Irvin (13) and Tiffany (6), were attacked in their home. Escober was employed as a security guard for Bee Seng Electrical Supply, which is owned by Chua. The security guard on duty, Domingo Rocero, left his post around 7:30 PM and was later witness to events involving Abuyen (one of the alleged co-conspirators), who, with others, conspired to commit robbery and murder. After Rocero's shift, Vicente Chua entered the premises with his children only to have them brutally attaCase Digest (G.R. No. L-11647)
Facts:
- Origin and Procedural Background
- The consolidated cases originated from the decision rendered by Judge Oscar Leviste of RTC Quezon City, Branch XCVII, in Criminal Case No. Q-22896.
- The decision, issued on January 10, 1984, found accused Juan Escober y Geralde and Macario Punzalan, Jr. y Guevarra guilty beyond reasonable doubt of Robbery with Homicide.
- The trial court sentenced Escober to the death penalty (later automatically reviewed) and imposed joint and several liabilities for compensatory and moral damages against the accused, while subsequently convicting Punzalan on similar charges.
- Following the decision, motions for reconsideration were filed by the defense but were denied by the trial court.
- Separate petitions were elevated to the Supreme Court (G.R. Nos. 69564 and 69658), with Escober seeking to cut short his prolonged wait for final resolution and Punzalan arguing for reversal on constitutional grounds.
- Chronology of the Crime
- On December 3, 1982, at the Bee Seng Electrical Supply, Inc. compound in Quezon City, a robbery coupled with a homicide occurred.
- Accused Juan Escober, then a security guard on duty, along with four unidentified persons designated “John Doe, Peter Doe, Richard Doe and Juan Doe” and co-accused Macario Punzalan, Jr., were charged for their alleged participation in the crime.
- The crime occurred within a short span (approximately 5–10 minutes) during which the compound’s gate was opened and subsequently the victims’ household was invaded, leading to the stabbing and death of two children.
- The crime scene revealed open drawers with scattered contents, missing cash from one drawer, and a blood-stained scissor blade identified as Exhibit “E.”
- Evidence and Witness Testimonies
- Prosecution Evidence
- Testimonies from multiple witnesses including Vicente Chua, Mrs. Lina Chua, security guards Domingo Rocero and others.
- Documented physical evidence such as sketches of the victims’ stab wounds, the recovered blood-stained blade, and police reports from Investigator Oscar Francisco.
- Chain of events included:
- Escober, on duty, opened the compound’s gate upon a knock; a fact later emphasized by the prosecution as an “unlikely garbage throwing reason” to facilitate the entry of alleged robbers.
- Defense Evidence
- Direct testimony by accused Escober detailed his routine as a security guard, his arrival on duty, and his explanation for opening the gate, which he claimed was a natural act rather than evidence of conspiracy.
- Escober’s account minimized his role by emphasizing that he left his gun in the locker and that his actions were dictated by habit rather than participation in a criminal plan.
- Punzalan’s testimony highlighted inconsistencies in the prosecution’s evidence and underscored the manner in which he was interrogated, including alleged violations of his constitutional rights during custodial investigation.
- Discrepancies and Gaps
- The trial judge’s decision did not sufficiently itemize the specific evidence or properly indicate which testimonies or exhibits supported each finding.
- The decision was brief (approximately 1½ pages) and contained handwritten insertions, failing to meet the detailed requirement mandated by Section 9, Article X of the 1973 Constitution.
- Nature of the Criminal Offense
- The crime charged was Robbery with Homicide, where the killing of the two children occurred during the commission of a robbery.
- The prosecution sought to establish that both accused acted as principals by indispensable cooperation in a criminal conspiracy even though not all directly executed the homicidal act.
- The doctrine applied by the prosecution rested on the notion that in a conspiracy the act of one is the act of all, with the additional allegation that Escober’s act of opening the gate and subsequent movements contributed to the planned criminal act.
Issues:
- Compliance with Constitutional Requirements
- Whether the trial court’s decision, being only 1½ pages long with generalized conclusions, met the requirement of Section 9, Article X of the 1973 Constitution to clearly and distinctly state the facts and the law supporting its conclusions.
- Sufficient Proof of Conspiracy and Participation
- Whether the evidence presented established beyond reasonable doubt that Juan Escober had the requisite knowledge of the conspiracy and acted as a principal through indispensable cooperation in the crime of Robbery with Homicide.
- Whether the alleged act of opening the gate, taken in isolation, sufficed to impute the nefarious design to Escober.
- Validity of Punzalan’s Statement and Constitutional Rights
- Whether Macario Punzalan, Jr.’s waiver of rights during the custodial investigation was intelligently and voluntarily made, given his low educational attainment and the manner in which his rights were explained.
- Whether the failure to properly inform him of his right to counsel prejudiced his defense during the custodial and preliminary investigations.
- Applicability of the Conspiracy Doctrine
- Whether the doctrine that “the act of one conspirator is the act of all” was appropriately applied, specifically in determining that all participants in the robbery were liable for the resultant homicide even if they did not directly commit the killing.
- Whether exceptions exist where a conspirator’s subsequent dissociation or failure to engage in a particular act (such as attempting to prevent the homicide) could absolve him of liability for the homicide.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)