Title
People vs. Ferdez y Dela Vega
Case
G.R. No. 218130
Decision Date
Feb 14, 2018
Two accused conspired in a robbery-homicide; one’s coerced confession deemed inadmissible, but circumstantial evidence and conspiracy upheld their guilt. Damages adjusted.
A

Case Digest (G.R. No. 218130)

Facts:

People of the Philippines v. Hermie Paris y Nicolas, accused, and Ronel Fernandez y Dela Vega, accused-appellant, G.R. No. 218130, February 14, 2018, Supreme Court First Division, Del Castillo, J., writing for the Court. In an Information dated June 17, 2011, respondents Paris and Fernandez were charged with robbery with homicide allegedly committed on or about June 15–16, 2011 at Anna Leizel Trading and Construction Supply in Binmaley, Pangasinan (offense described as violation of Article 293 in relation to Articles 294 and 299 of the Revised Penal Code). At arraignment both pleaded not guilty; at pre-trial the parties stipulated as to place, identities, and that Fernandez was a stay‑in worker at the establishment.

The prosecution’s case was that Fernandez opened the warehouse gate and allowed Paris and two companions to enter; they then went to the victim Reymark Salvador’s room, thereafter to Anna Leizel Abagat’s office where they took cash and jewelry, and Salvador was later found stabbed to death. Fernandez later informed the employer and was taken to the police station where he executed an extrajudicial confession in the presence of Atty. Franco Francisco; an autopsy established multiple stab wounds as cause of death. The defense version was that Fernandez was accosted, blindfolded and restrained by Paris’ companions, threatened, and coerced into admitting participation; Fernandez claimed physical abuse by police and that counsel only assisted after the written confession was produced. Paris denied involvement and offered an alibi supported by his sister.

On January 22, 2013 the Regional Trial Court (RTC), Branch 69, Lingayen, Pangasinan, found both Paris and Fernandez guilty of robbery with homicide and sentenced them to reclusion perpetua, holding Fernandez’s extrajudicial confession admissible; the RTC also awarded civil and moral damages and other monetary relief. Paris and Fernandez appealed to the Court of Appeals (CA). On July 21, 2014 the CA affirmed the conviction but modified the awards...(Subscriber-Only)

Issues:

  • Was appellant Fernandez’s extrajudicial confession admissible in evidence?
  • If the extrajudicial confession is inadmissible, is there nevertheless sufficient circumstantial evidence to convict Fernandez of robbery with homicide and to establish conspiracy making him li...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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