Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Salvador Espanol y Elmeranes, Nicanor Rivera y Bartolata, and Pablito Bomballes y Llabres, the accused-appellants. The events transpired in the early morning hours of December 24, 1979, at the residence of Juan Arellano located at 7855 Makati Avenue, Makati, Metro Manila. Anselma Marcelo-Arellano, 32, and her housemaid, Cirila Moscoso, 20, were brutally murdered in the master bedroom. During the incident, cash and checks totaling P140,908.50 were stolen from Arellano's safe, and an attempt was made to strangle his three-year-old daughter, Catherine. The police recovered the stolen items shortly after the crime.

An autopsy revealed that Anselma died from asphyxia due to strangulation, while Cirila suffered fatal injuries to her brain. The three accused, all employees at the Arellano wine and liquor store, were interrogated by the police. Salvador Espanol confessed to conspiring with Rivera...

Facts:

Incident Overview

• Between 2:00 and 3:00 AM on December 24, 1979, Anselma Marcelo-Arellano (32) and her housemaid, Cirila Moscoso (20), were killed in the master bedroom of Juan Arellano’s residence at 7855 Makati Avenue, Makati, Metro Manila.
• Cash and checks amounting to ₱140,908.50 were stolen from the safe in the bedroom.
• An attempt was made to choke Catherine Arellano, the 3-year-old daughter of Anselma, who was also in the bedroom.

Autopsy Findings

• Anselma Marcelo-Arellano: Contused abrasions on the chin, left jaw, and neck; fracture in the thyroid region; death due to "asphyxia by strangulation."
• Cirila Moscoso: Contused abrasions and hematoma in the head, neck, and shoulders; death due to brain injuries.
• Catherine Arellano: Abrasion on the neck and hematoma on the shoulder.

Confessions and Statements

• Salvador Espanol, Nicanor Rivera, and Pablito Bomballes, all employees at the Arellano wine and liquor store, were arrested and gave statements.
• Espanol confessed to conspiring with Rivera and Bomballes to steal money from the safe. He admitted to striking Anselma and Cirila with a lead pipe and attempting to choke Catherine.
• Bomballes and Rivera gave conflicting statements, each attempting to minimize their involvement.

Trial Proceedings

• Espanol pleaded guilty to the charges, while Rivera and Bomballes pleaded not guilty.
• The trial court convicted Espanol of robbery with homicide, homicide, and attempted murder, sentencing him to death for the first charge and imposing lesser penalties for the others.
• Rivera and Bomballes were initially convicted as accessories to simple robbery but were later reclassified as accessories to robbery with homicide after a motion for reconsideration by the prosecution.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Special Complex Crime of Robbery with Homicide: The Court emphasized that the crime of robbery with homicide remains fundamentally the same regardless of the number of persons killed or injured during the robbery. All homicides and attempted murders committed by reason or on the occasion of the robbery are merged into the single complex crime.
2. Aggravating Circumstances: Abuse of confidence was validly appreciated because Espanol was trusted by his employers, and treachery was present in the manner of the killings. However, dwelling was not applicable since Espanol did not share the same living space as the victims.
3. Finality of Judgment: A judgment becomes final after the lapse of the period for appeal or when the defendant waives the right to appeal. The trial court could not amend the judgment after it had become final, as in the case of Rivera and Bomballes.

Disposition

• The Supreme Court modified the trial court’s judgment, convicting Espanol of robbery with double homicide and attempted murder and sentencing him to death. The convictions for separate offenses of homicide and attempted murder were set aside.
• The amendatory order increasing the penalties for Rivera and Bomballes was set aside, and they were ordered to be released immediately unless detained for other offenses.