Case Digest (G.R. No. 122142)
Facts:
The People of the Philippines v. Jimmy Obrero y Corla, G.R. No. 122142, May 17, 2000, the Supreme Court Second Division, Mendoza, J., writing for the Court. The appellant is Jimmy Obrero y Corla (accused‑appellant); the prosecution is the People of the Philippines (plaintiff‑appellee). The Regional Trial Court (RTC), Branch 12, Manila (Judge Rosmari D. Carandang), convicted Obrero of robbery with homicide under Article 294(a) of the Revised Penal Code and sentenced him to reclusion perpetua, ordered indemnities of P50,000 for each deceased victim and P4,000 as the amount stolen.The information charged that on or about August 11, 1989 the accused, together with an unapprehended companion (later identified as Ronnie Liwanag), robbed the residence of Emma Cabrera and that during the robbery two household helpers, Nena Berjuega and Remedios Hitta, were stabbed to death. Only Obrero was apprehended. At arraignment he pleaded not guilty and trial followed.
At trial the prosecution presented Patrolman Benjamin Ines (investigator), Dr. Marcial Cenido (medico‑legal officer), and Atty. Bienvenido De los Reyes. Patrolman Ines narrated the investigation, how Obrero had worked as a delivery boy for Angie Cabosas, had delivered chickens to the Cabrera residence on the morning of August 11, 1989, and was later located and arrested in Pangasinan on March 4, 1990. Ines identified sworn statements by a househelp (Helen Moral, Exhibit I) and by Anita De los Reyes (Exhibit L), the latter stating she saw Obrero and Ronnie Liwanag running down stairs with blood on their hands. Ines also identified an extrajudicial written confession signed by Obrero on March 4, 1990 (Exhibit O).
Atty. De los Reyes testified that he assisted Obrero during the custodial interrogation, that he advised Obrero of his constitutional rights, and that Obrero voluntarily gave a statement. Dr. Cenido testified to multiple fatal stab wounds on both victims and opined the wounds could have been inflicted by one or more assailants using a single‑bladed weapon. The prosecution rested on the testimonies, the medico‑legal reports, the two sworn statements, and Obrero’s extrajudicial confession (Exh. O).
Obrero testified in his own defense, denied participation, claimed he was arrested without warrant, alleged he was beaten and detained for a week, and insisted the extrajudicial confession was involuntary and that he did not understand it because he could not read. He further claimed Atty. De los Reyes was not counsel of his choice.
The RTC found the extrajudicial confession voluntary and corroborated by details and the medico‑legal findings, convicted Obrero, and imp...(Subscriber-Only)
Issues:
- Was the extrajudicial confession (Exhibit O) admissible given the requirements of counsel and Miranda warnings under the Constitution?
- If Exhibit O is inadmissible, was there otherwise sufficient admissible evidence to sustain appellant’s conviction beyond...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)