Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Wilfredo Lara, the accused-appellant, along with several co-accused including Ferdinand Suarez, Loreto Reyes, and others. The events transpired in the early hours of December 8, 1987, at the residence of Estrellita Guzman located at 22 Sta. Teresita Street, Barrio Capitolyo, Pasig, Metro Manila. Arlene Tuyor, a domestic helper, was awakened by loud knocking on her door and found Ferdinand Suarez, also known as "Jojo," surrounded by two masked men. The intruders tied Tuyor up and abducted Suarez. After the intruders left, Tuyor discovered Estrellita Guzman bleeding in her bedroom, who later succumbed to her injuries from stab wounds. The police investigation revealed that the intruders had forcibly entered the house, and evidence such as ropes, cloths, and a half-eaten chicken was found at the scene.

Ferdinand Suarez later recounted that he was attacked by six men in his home, who th...

Facts:

1. The Crime Scene and Initial Events:

• On December 8, 1987, Arlene Tuyor, a domestic helper, was awakened by loud knocking on her door at Estrellita Guzman’s house in Pasig, Metro Manila.
• Ferdinand Suarez (Jojo), Estrellita’s son-in-law, was seen with two masked men who tied Tuyor and demanded money.
• The intruders left Tuyor’s room and proceeded to other parts of the house. Tuyor heard the microwave oven being used and the main door slamming shut.
• Estrellita Guzman was found bleeding and later died from stab wounds. Post-mortem examinations revealed multiple wounds, including an incised wound on her left thumb.

2. Police Investigation:

• Police found evidence at the scene, including black nylon cloths, ropes, wires, and a half-eaten chicken.
• The kitchen door showed signs of forced entry, but the dead bolt lock was intact, suggesting the intruders had inside help.
• Ferdinand Suarez initially claimed he was a victim, stating he was tied and gagged by the intruders.

3. Involvement of Ferdinand Suarez:

• The National Bureau of Investigation (NBI) suspected Suarez’s involvement due to the lack of injuries on him and his strained relationship with Estrellita.
• Suarez eventually confessed to aiding the intruders, revealing that Loreto Reyes (Dondon) had approached him to plan the robbery. Suarez provided duplicate keys to the house and disengaged the bolt lock to facilitate the intruders’ entry.

4. Loreto Reyes’ Confession:

• Reyes admitted his role in the crime, implicating Wilfredo Lara as the one who introduced Suarez to the group.
• Reyes detailed how the group entered the house, tied the occupants, and stole valuables. He also admitted that Suarez instructed them to kill Estrellita.

5. Wilfredo Lara’s Role:

• Lara confessed to introducing Suarez to Reyes and the group but denied participating in the actual robbery.
• He claimed he was not present during the crime and did not receive any share of the loot.

6. Trial and Conviction:

• Suarez, Reyes, and Lara were charged with robbery with homicide. The trial court found them guilty based on their confessions and circumstantial evidence.
• Suarez and Reyes accepted the verdict, but Lara appealed, challenging the admissibility of his confession, claiming it was obtained through coercion and without proper legal assistance.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Voluntariness of Confessions:

   • A confession is presumed voluntary unless the accused proves it was obtained through violence, intimidation, or other improper means. The burden of proof lies with the accused to show that the confession was involuntary.
   • The presence of counsel during custodial investigation ensures the voluntariness of the confession, and the failure of the accused to object to the appointed counsel implies consent.

2. Doctrine of Interlocking Confessions:

   • The confessions of co-accused can be used as corroborative evidence to establish the guilt of another accused, provided the confessions are independently made and consistent in essential details.
   • The doctrine of interlocking confessions is an exception to the hearsay rule and the res inter alios acta rule.

3. Accomplice Liability:

   • An accomplice is someone who, without being a principal, cooperates in the execution of the crime by previous or simultaneous acts. Lara’s role in introducing Suarez to the group was insufficient to classify him as a principal.
   • When the extent of an accused’s participation is uncertain, the benefit of the doubt should be given, and the accused should be declared an accomplice rather than a principal.

4. Penalty Modification:

   • The Court has the authority to modify penalties based on the degree of participation and the evidence presented. Lara’s minimal role warranted a reduction in his sentence.