Case Digest (G.R. No. 199067)
Facts:
In People of the Philippines vs. Ronilo Pinlac y Libao, G.R. Nos. 74123-24, decided on September 26, 1988, the accused-appellant, Ronilo Pinlac y Libao, was charged with two separate offenses arising from incidents on April 8, 1984 in San Lorenzo Village, Makati, Metro Manila. In Criminal Case No. 10476, he was accused of forcefully entering the residence of Koji Sato through detached window jalousies and aluminum screens and stealing cash (₱180), an Alba (Seiko) wristwatch (₱300), a gold necklace and pendant (undetermined value). In Criminal Case No. 10477, he was alleged to have slashed the screen wall of Saeki Osamu’s home, stolen a Hitachi cassette tape recorder (undetermined value), and, in the commission of the robbery, stabbed Osamu several times, causing his death. After a full trial, the Regional Trial Court of Makati (Branch 145) convicted Pinlac of robbery in Case No. 10476, sentencing him to six (6) years of prision correccional as minimum to eight (8) years and one
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Case Digest (G.R. No. 199067)
Facts:
- Parties, Background and Premises
- Accused Ronilo Pinlac y Libao was married to Delia Marcelino, cook for Japanese national Koji Sato, who also employed maid Irene Jandayan; both victims rented adjacent houses in San Lorenzo Village, Makati.
- Neighbor Saeki Osamu, a staff member of the Japan International Cooperation Agency, lived next door with maid Evelyn Salomea.
- Robbery and Homicide of April 8, 1984
- Criminal Case No. 10476: Pinlac removed four window jalousies and aluminum screens at Sato’s servants’ quarters, stole P180 cash, a P300 Alba Seiko wrist watch, a gold necklace and other articles.
- Criminal Case No. 10477: Pinlac slashed Osamu’s screen wall, stole a Hitachi cassette tape recorder, then stabbed Osamu several times with a kitchen knife, causing mortal wounds.
- Investigation, Evidence and Confession
- Police investigators recovered the murder weapon (Exhibit Q), took photographs, lifted fingerprints and collected footprints matching Pinlac’s shoes; Jandayan and Salomea gave sworn statements (Exhibits B, Z, AA).
- Pinlac was arrested without a warrant at Marcelino’s residence, forced to reenact the crime, allegedly tortured for seven hours (sustaining cuts and bloodied lips), and signed extra-judicial confessions (Exhibits F, F-1, F-2) without counsel.
- Trial Court Proceedings and Conviction
- The Regional Trial Court convicted Pinlac of robbery (Case No. 10476), sentencing him to 6–8 years’ imprisonment and P500 damages, and of robbery with homicide (Case No. 10477), sentencing him to death and P30,000 damages.
- Pinlac’s defense challenged the confession’s admissibility for lack of Miranda warnings and counsel, alleged torture, and contended fingerprint evidence resulted from police-directed reenactment.
Issues:
- Admissibility of the Accused’s Extra-Judicial Confession
- Was the confession obtained in violation of Pinlac’s constitutional rights to be informed of his right to remain silent and to counsel?
- Was the confession invalid for lack of counsel during custodial interrogation and for being coerced under torture?
- Sufficiency and Legality of Evidence Supporting Conviction
- Does the circumstantial evidence (prints, footprints, witness statements) establish guilt beyond reasonable doubt in the absence of direct eyewitness identification?
- Did the prosecution’s failure to rebut the defense’s explanation of fingerprint/footprint evidence or to present untainted evidence undermine the conviction?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)