G.R. No. L-45354 - People vs. Newman y Beclar

On March 19, 1975, in Bacolod City, Efren Bantillo was attacked by two individuals, later identified as Albert Newman y Beclar and Dionisio Tolentino y Santillan.
The accused were charged with the crime of Robbery with Homicide for having, by means of violence and with a knife, inflicted fatal stab wounds on Bantillo and then robbed him of personal effects.

The information in the charge stated that the accused, while armed with a knife and acting in concert, inflicted multiple stab wounds on the victim—including wounds to the left hypochondriac region, the chest cavity, and the abdomen—that eventually led to Bantillo’s death.
Among the items allegedly taken from the victim were a Ceba wristwatch, a wallet with pertinent papers, and a comb, with a theft value of P500.00.
The victim’s wounds were severe, including penetration of the abdominal cavity with omentum prolapse and severe internal hemorrhage, as well as chest wounds damaging the diaphragm and liver, demonstrating the lethality of the attack.

Rosita Empio, a nearby bystander selling coffee, recounted the incident when the taxi (PU Minica) carrying Bantillo stopped at her store, and she later assisted by binding the victim’s wound.
Other witnesses, including Felix, Kiko Luces, and patrolmen, provided accounts of the victim’s condition and the sequence of events immediately following the attack.

Patrolman Eduardo Yanson, along with other officers, conducted preliminary interviews with the wounded victim and secured physical evidence from the scene.
Subsequent investigations included a formal re-enactment of the crime involving the accused under police supervision, which was photographed and marked as evidentiary exhibits.

The wristwatch recovered from Albert Newman and the driver’s license (with a substituted identification photo) recovered from Dionisio Tolentino were key pieces linking the accused to the crime.
Additional evidence such as money, comb, and photographic documentation of the re-enactment substantiated the sequence of events.

Both accused, after their arrest, were subjected to custodial investigation procedures.
They were required to sign waivers of their right to remain silent and to counsel, and were interrogated by police investigators in a police-denominated environment.
Extra-judicial confessions were executed by both accused, although these confessions were later repudiated by the accused and became a central point of contention.

The trial court found both Albert Newman and Dionisio Tolentino guilty beyond reasonable doubt of Robbery with Homicide.
The verdict imposed reclusion perpetua on both and ordered them to pay indemnity to the heirs of the deceased.
The decision also mandated the return of the recovered items (wristwatch, comb, money, and personal effects) to the victim's heirs.

Whether the accused were effectively informed of their constitutional rights (to remain silent and to counsel) during the custodial interrogation.
If the extra-judicial confessions, which were later repudiated, should be excluded from evidence due to improper advisement and the mechanical nature of the constitutional warnings provided.

Whether the re-enactment of the crime, conducted under police direction and supported by photographs, was voluntary or coerced.
The impact of the scripted re-enactment on the credibility and admissibility of that evidence.

The extent to which the actions and associations of the accused indicate a concerted effort or conspiracy in the commission of the crime.
Whether the circumstantial and physical evidence, including possession of the stolen items, suffices to impute joint responsibility for the homicide and robbery.