Facts:

The case involves Oscar Robles y Moana (appellant), Antonio Manas y Flava, and Vicente Antonio y Haya as the accused. The incidents occurred on January 30, 1987, around 1:00 P.M., in the vicinity of Del Pan Street, Tondo, Manila. While on routine patrol, Patrolmen Rey Cocson, Edgar Amurao, and C. Tabanera noticed suspicious behavior from two male passengers in a taxicab. The policemen signaled the taxi to stop for inspection, and upon questioning, Robles and Manas hesitated to identify the ownership of two bags in the cab. Robles eventually confessed, admitting their involvement in the robbery of Jose Macalino's residence in Makati. During the frisking, Robles was found with a .38-caliber revolver, while Manas had a fan knife (balisong). The police discovered a variety of stolen goods in the bags. Following the arrest, they reached Macalino's home, which had been ransacked, and found the bodies of two deceased individuals, identified as household helpers Marilou Dalugdug

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Facts:

Incident and Apprehension

• On January 30, 1987, at around 1:00 P.M., three patrolmen (Cocson, Amurao, and Tabanera) on a routine patrol near Del Pan Street, Tondo, Manila, observed a taxicab carrying two male passengers whose furtive behavior raised suspicion.
• The police signalled the taxi to stop; upon stopping, the officers questioned the occupants and noted the presence of two bags on the back seat.
• The occupants were later identified as Antonio Manas y Flava (seated beside the driver) and Oscar Robles y Moana (seated at the back).
• When asked about the bags, the accused initially refused to admit ownership, but Robles eventually broke down and confessed that the bags contained items stolen from the residence of Jose Macalino in Makati.

Discovery of the Crime Scene and Evidence

• After the initial apprehension, a thorough inspection of the bags revealed stolen items such as shoes, cameras, watches, and assorted articles.
• A .38 caliber revolver was found on Robles during a frisk, while a fan knife (balisong) was recovered from Manas.
• A nametag on one bag led police to contact Beth M. Puzon, daughter of Macalino, linking the stolen items to her father’s residence.
• Detective Ernesto Gatpayat subsequently investigated the home of Jose Macalino in Makati and found it ransacked with two dead persons inside, later identified as household helpers Marilou Dalugdugan and Diego Limato.
• A screwdriver was discovered beside the body of Dalugdugan, indicative of its use as a weapon.

Statements and Pre-trial Proceedings

• After being apprised of their constitutional rights, Robles and Manas were taken to police headquarters and later turned over to the Makati Police Department.
• In their custodial investigation, assisted by counsel (Atty. Eugenio Macababayao, Jr.), both accused gave extrajudicial statements.
• Robles, a 29-year-old tinsmith, admitted his participation in the robbery but denied involvement in the killings; he testified that he acted as a lookout while the actual robbery and subsequent killings were committed by Manas and Antonio.
• Contrarily, Manas, a 39-year-old housepainter, admitted responsibility for killing Dalugdugan by stabbing her with a screwdriver, while also noting that Robles was inside the house at the time.
• The Information for Robbery with Double Homicide was filed on February 5, 1987, and later amended to include Vicente Antonio y Haya (alias “Ric”), who remains at large.

Trial Developments and Evidentiary Stipulations

• During pre-trial, both the prosecution and defense agreed on several key facts:
• The identity and cause of death of the victims.
• The genuineness of the postmortem examination certificates issued by Dr. Mariano Cueva, Jr.
• The ownership, existence, and eventual recovery of the stolen articles belonging to Jose Macalino.
• The authenticity and evidentiary value of the sworn Statements (Malayang Salaysay) given by Robles (Exhibit "C") and by Manas (Exhibit "D"), despite defense claims of intimidation.
• The prosecution’s primary witnesses included:
• Det. Ernesto Gatpayat, who discovered the bodies and took statements from Macalino.
• Aida Pascual, a Forensic Chemist who testified about the blood types recovered from the weapons and the victims.
• Patrolmen Rey Cocson and Celso Noriega, who provided testimonies on the apprehension, identification of stolen property, and the custodial investigation.
• The defense, including testimony of Robles and Manas, contested the attendance and validity of their extrajudicial confessions, alleging police threats and inconsistent statements regarding their whereabouts at the time of the robbery and killings.

Judgment and Post-Trial Issues

• On March 30, 1989, the RTC of Makati, Branch 148, rendered a decision convicting Robles (and co-accused Manas, whose appeal was not heard) for the complex crime of Robbery with Homicide.
• The accused were sentenced to reclusion perpetua and jointly ordered to pay indemnity to the heirs of each victim.
• During appeal, appellant Robles contested:
• The admissibility of his extrajudicial confession, claiming it was obtained under duress and without proper counsel, and
• The sufficiency of circumstantial evidence linking him beyond reasonable doubt to the crime.
• The appellate court’s later analysis and decision discussed both procedural and substantive evidence issues, leading to affirmation of much of the trial court’s findings with modifications regarding the quantum of indemnity and additional exemplary damages.

Issue:

Admissibility of the Extrajudicial Confession

• Whether the extrajudicial confessions of Robles and his co-accused were admissible despite allegations of threats and absence of effective assistance of counsel during custodial investigation.
• Whether the presence of counsel, as demonstrated by Atty. Eugenio Macababayao, Jr., throughout the investigation and trial, nullified claims of an invalid or coerced confession.

Sufficiency of Circumstantial Evidence

• Whether the circumstantial evidence presented, including the recovered stolen goods, the discovery of weapons, the uncovering of the crime scene with two dead bodies, and the role of Robles as a lookout, was sufficient to prove his participation in the complex crime of Robbery with Homicide beyond reasonable doubt.
• Whether appellant’s mere presence in the taxicab and subsequent events could exculpate him from accountability in light of his admitted involvement in the robbery and his participation in looting the residence.

Related Procedural Objections and Issues

• The belated attempt by appellant Robles to question the validity of his arrest for failure to be informed of his Miranda rights, and whether such objections were properly preserved given his active participation in trial proceedings.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)