Facts:
On November 28, 1969, the case
The People of the Philippines vs. Manuel Marquez, Tomas Navasca, Andres Alcontin, Rogelio Alcontin and Florencio Geraldez involved two criminal prosecutions consolidated in a single trial by the Davao Court of First Instance. Criminal case 7050 (L-24373) charged the five accused with
robbery in band with homicide committed on May 14, 1961 in Matanao, Davao. Criminal case 7054 (L-24374) charged them with
robbery in band with multiple rape committed about a month earlier, specifically on April 15, 1961 in Bansalan, another municipality in the same province. After a simultaneous trial, the trial court convicted all defendants in both cases and imposed different penalties: in criminal case 7050, the trial court imposed
reclusion perpetua (life imprisonment) for each accused and ordered indemnities for the heirs of the deceased and for the value of the properties robbed; in criminal case 7054, it imposed
indeterminate imprisonment of *not less than* certain minimum terms and *not more than*
reclusion temporal as maximum for the accused, with indemnities for the value of the properties robbed. The trial court credited
voluntary plea of guilty as a mitigating circumstance in criminal case 7050 for
Tomas Navasca, while the other accused did not receive the same mitigation. All defendants appealed directly to the Court of Appeals, which declined to pass upon criminal case 7054, reasoning that the two cases involved a single consolidated record and common evidence, and that reviewing both matters by separate appellate tribunals might create conflict. Instead, the Court of Appeals certified the cases to the Supreme Court for review. The Supreme Court held it could only review criminal case 7050 because the penalty in that case placed it within its
exclusive appellate jurisdiction. On the merits of criminal case 7050, the Court examined the plea situation of
Tomas Navasca, who entered a
plea of guilty at arraignment on January 17, 1962, but whose counsel sought reconsideration on the claim that he had previously agreed to plead not guilty and had later become mentally deranged while in prison. The trial court ordered psychiatric examination, and
Dr. Manuel Celis testified and reported that Navasca suffered from “
schizophrenic reaction” (simple and hebephrenic schizophrenia), yet also declared that the schizophrenic effect on comprehension was “merely superficial,” and that Navasca could still understand the proceedings and the meaning of the inquiries made. The trial court found Navasca
legally sane and rejected the demand to change the plea to one of
not guilty, and the Supreme Court agreed. As to the robbery in band with homicide itself, the Supreme Court relied on the testimony of
Regina But-ay and
Crisanta But-ay, who narrated that on May 14, 1961, five armed robbers invaded the But-ay residence in New Visayas, Matanao, Davao, with four barging in through the front door and the fifth guarding or controlling the occupants. Crisanta was brought to the second floor, where she identified
Rogelio Alcontin as the person who hauled her up,
Andres Alcontin as the one ransacking a trunk, and
Florencio Geraldez as the one who went upstairs with her aunt. Shots were heard from the kitchen area, and
Regina and
Crisanta identified
Manuel Marquez as demanding bullets and later pressing Regina for money; they also identified
Andres Alcontin as accompanying Marquez when Regina was made to point to the bodega. Regina testified that she saw
Nicolas Amaba dead on the floor with gunshot wounds causing massive internal hemorrhage leading to shock and death. After Marquez ordered a turning of the body, Marquez asked where the husband was; when there was no money at the bodega, Marquez hit Regina with a stool. The robbers left at about 7 o’clock in the evening, taking money and valuables assessed at
P856. The Supreme Court noted the record did not itself detail inculpatory evidence against Navasca beyond the
accepted guilty plea, but it held that omission did not reduce the probative value of the State witnesses’ narration as to the others. The Court rejected the
alibi raised by
Rogelio Alcontin, finding it insufficient because the testimony offered merely placed Rogelio at another place for an over-a-month period and did not establish physical impossibility. The Court also treated as academic the assigned error on denial of continuance, because the requested corroborative testimonies would be superfluous after the Court effectively disregarded the confessions. The Court then addressed the proper penalty for robbery in band with homicide in light of the governing provisions of the Revised Penal Code and relevant jurisprudence.
Issues:
- Whether Tomas Navasca was legally sane at the time of arraignment such that his plea of guilty could be accepted, or whether he should have been committed and his arraignment suspended.
- Whether the evidence sufficiently established the guilt of Manuel Marquez, Andres Alcontin, Rogelio Alcontin, and Florencio Geraldez for robbery in band with homicide, including identification of the accused and the credibility of alibi and other defenses.
- Whether the proper penalty for the offense in criminal case 7050 was correctly imposed, and whether the Court’s appellate jurisdiction required it to decide criminal case 7054 in the same proceeding.
Ruling:
Ratio:
Doctrine: