Title
People vs. Robles
Case
G.R. No. 101335
Decision Date
Jun 8, 2000
Oscar Robles and Antonio Manas were convicted of robbery with double homicide, with their extrajudicial confessions deemed admissible as evidence.
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Case Digest (G.R. No. 101335)

Facts:

  • The case involves the People of the Philippines as the plaintiff-appellee against Oscar Robles y Moana, Antonio Manas y Flava, and Vicente Antonio y Haya, the accused.
  • The Supreme Court rendered its decision on June 8, 2000, concerning Criminal Case No. 28829 from the Regional Trial Court of Makati, Branch 148.
  • On January 30, 1987, police officers were patrolling Del Pan Street in Tondo, Manila, when they flagged down a taxi with two male passengers, Robles and Manas.
  • The officers observed suspicious behavior, leading to a routine inspection.
  • Robles confessed to robbing the house of Jose Macalino in Makati, while Manas remained silent.
  • A search revealed a .38 caliber revolver with Robles and a balisong with Manas, along with bags containing stolen items.
  • Two dead bodies were found in Macalino's ransacked house, identified as Marilou Dalugdugan and Diego Limato, both household helpers.
  • Detective Ernesto Gatpayat discovered a screwdriver next to Dalugdugan's body.
  • Robles confessed to participating in the robbery but denied involvement in the killings, claiming he was a lookout.
  • Manas admitted to stabbing Dalugdugan to silence her while Antonio killed Limato.
  • The prosecution filed an Information for Robbery with Double Homicide against Robles and Manas, who pleaded not guilty.
  • The trial included testimonies from police officers and forensic experts, while the defense argued coercion in Robles' confession.
  • On March 30, 1989, the trial court convicted Robles and Manas of Robbery with Homicide, sentencing them to reclusion perpetua and ordering indemnity to the victims' heirs.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the extrajudicial confession of Oscar Robles is admissible against him.
  • The Court found sufficient circumstant...(Unlock)

Ratio:

  • The Supreme Court held that the extrajudicial confessions made by Robles and his co-accused were admissible, as they were assisted by counsel during the custodial investigation.
  • Atty. Eugenio Macababayao was present throughout the investigation, and Robles did not raise claims of coercion during the investigation or trial.
  • The Court emphasized that objections to the arrest must be raised before entering a plea, which Robles failed to ...continue reading

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