Case Digest (G.R. No. 111193)
Facts:
In People of the Philippines v. Ferdinand Suarez, et al., G.R. No. 111193, January 28, 1997, the Supreme Court Second Division, Regalado, J., writing for the Court, resolved an appeal by Wilfredo Lara from his conviction for robbery with homicide by the Regional Trial Court (Branch 152) of Pasig, Criminal Case No. 72249.In the early hours of December 8, 1987, intruders entered the home of Estrellita Guzman in Pasig. The household included Guzman, her adopted nieces Babyruth and Cristy, Maria Victoria Suarez (Marivic), her husband Ferdinand Suarez (Jojo) and their children, and the maid Arlene Tuyor. The intruders tied and gagged several occupants, ransacked the house and left with valuables; Estrellita was later found fatally stabbed. Police and NBI investigators recovered duplicate keys, black nylon masks, ropes, and other items at the scene; the kitchen door’s bolt remained intact, suggesting inside assistance.
During custodial investigations, Suarez, Loreto Reyes and Lara each gave sworn extrajudicial statements implicating themselves; Reyes and Lara confessed participation and described planning and execution, while Suarez admitted allowing the group access and assisting on the night. Reyes and Lara later retracted, alleging coercion and lack of effective counsel; Suarez maintained a different version at trial. The NBI recovered duplicate keys and other corroborative evidence. Based on those statements and other evidence, the provincial fiscal filed information charging robbery with homicide against Suarez, Reyes, Lara and others (some fugitives). Suarez, Reyes and Lara were tried; the trial court convicted the three and sentenced them to reclusion perpetua and awarded indemnities.
Only Lara appealed to the Supreme Court contesting, chiefly, the admissibility of the extrajudicial confessions (marked Exhibits O, P and Q) as involuntary and procured without effective counsel. Suarez and Reyes did not perfect appeals and their convictions were ...(Pro-only)
Issues:
- Were the extrajudicial confessions of Loreto Reyes and Wilfredo Lara admissible against Lara, notwithstanding their retractions and claims of coercion and absence of effective counsel?
- What is the proper criminal liability and penalty of Wilfredo Lara for the robbery with homicide charged — principal, accomplice, or other — and what...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)