Case Digest (G.R. No. 200537)
Facts:
People of the Philippines v. Rodrigo Quitolay Balmonte, G.R. No. 200537, July 13, 2016, Supreme Court Third Division, Perez, J., writing for the Court.The prosecution charged Rodrigo Quitolay Balmonte (accused-appellant) by Information dated March 19, 2008 with the special complex crime of Robbery with Homicide (Art. 294, par. 1, Revised Penal Code as amended by R.A. 7659) for the killing of Maria Fe Valencia y Supan and the alleged taking of her money, cellphone and jewelry on or about March 15, 2008 in Urdaneta City, Pangasinan.
At arraignment the accused initially pleaded GUILTY but later withdrew that plea and pleaded NOT GUILTY. The prosecution presented an investigation report and physical exhibits from the scene (broken knife with blood, hair strands, bloodstains), logbook entries placing the victim and the on-duty security guard (the accused) at the premises, and witness testimony including a coffee vendor, Chat Siquig Baculad, who saw the accused and his wife boarding the victim’s black car the morning after the killing. The victim’s black Mitsubishi Lancer was later surrendered to police by accused’s brother, Raffy. The accused abandoned his rented room and went into hiding until his arrest in Aklan on September 8, 2008.
While in the detention cell the accused gave an on-camera interview to ABS‑CBN reporter Joana Fe Tacason (Exhibit “U”), in which he admitted entering the victim’s room, taking money from her bag and, when asked, responded in the affirmative that he committed the act and said “Hindi ko na alam ang sumunod na nangyari.” The defense claimed the interview confession was made under extreme fear and without counsel and advanced alibi/denial that he left for Cubao and Aklan after his night duty.
The Regional Trial Court (Branch 47, Urdaneta City) convicted the accused of Robbery with Homicide in a Decision dated October 21, 2009 and sentenced him to reclusion perpetua; it awarded P50,000 as indemnity and P50,000 as moral damages. The accused appealed. The Court of Appeals, in a Decision dated May 13, 2011 (CA-G.R. CR.-H.C. No. 04237), affirmed the RTC. The c...(Subscriber-Only)
Issues:
- Was the accused-appellant’s extra-judicial confession made to a private news reporter admissible in evidence?
- Did the prosecution prove the accused-appellant’s guilt for Robbery with Homicide beyond reaso...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)