Title
People vs. Valera
Case
G.R. No. L-34356
Decision Date
May 31, 1979
Two police officers conspired to rob and murder a couple, using weapons and setting their house ablaze; both were convicted of robbery with double homicide.

Case Digest (G.R. No. L-34356)

Facts:

People of the Philippines v. Julio Valera and Ernesto Imperial, G.R. No. L-34356; G.R. No. L-37016, May 31, 1979, the Supreme Court En Banc, Per Curiam. The prosecution (the People) charged defendants Julio Valera and Ernesto Imperial with Robbery with Double Homicide for the killing of Marcial Jalotjot and Valeriana Hernandez and the subsequent taking of their property on the night of August 6, 1967 in Putingtubig, Barrio Lumangbayan, Pinamalayan, Oriental Mindoro.

The Information was filed September 23, 1967. Both accused initially pleaded not guilty (March 14, 1968). Imperial moved to withdraw his not-guilty plea and was re-arraigned; he first pleaded guilty on November 27, 1968 and was sentenced to death, but this judgment was set aside by this Court in G.R. No. L-30039 on February 8, 1972 and remanded for new arraignment. On November 28, 1972, Imperial again pleaded guilty; on February 22, 1973 the trial court found him guilty as co-principal of Robbery with Double Homicide, imposed death (with recommendation for commutation), and ordered indemnity to the heirs.

The trial of Valera proceeded; after extended proceedings (July 16, 1968 to August 9, 1971) the trial court convicted him of Robbery with Double Homicide and, on September 15, 1971, sentenced him to death and ordered indemnity P20,000. Valera had a prior final conviction (1954) and escaped custody while detained for the present case (September 11, 1968).

At Valera’s trial, the key prosecution witness was twelve‑year‑old Orlando Merza, who testified that Valera (a policeman) and Imperial came to the Jalotjot house, drank with the victims, and, while Merza watched, Imperial stabbed Marcial and Valeriana and Valera encouraged/participated (pointing a gun, striking Valeriana, tying Merza, and ransacking the house). Police found the victims’ bodies (autopsy by Dr. Fernando Viloria showing multiple fatal wounds), a bloodstained bolo (Exh. X), signs of ransacking and burning, and recovered the victim’s caliber .22 revolver and a transistor radio at locations indicated by Imperial and his wife. Imperial earlier gave a sworn statement (Exh. BB) implicating Valera; at various times Imperial admitted or retracted parts of his admissions. Valera testified and denied participation, alleging Imperial acted alone; Imperial’s testimony at Valera’s trial differed from his earlier sworn statement. The trial court rejected the defense and credited the prosecution; Imperial’s own conduct and admissions were relied upon in his re‑arraignment and conviction.

Both death sentences were subject to automatic review by the Supreme Court (the mode of review). The Solicitor General argued for reclassification of Imperial’s crime and mitigation for his plea; the trial court and this Court examined whether the plea of guilty in a capital case was entered...(Subscriber-Only)

Issues:

  • Was the guilt of defendants Julio Valera and Ernesto Imperial for Robbery with Double Homicide proven beyond reasonable doubt?
  • Were aggravating circumstances established to justify imposition of the death penalty?
  • Was Ernesto Imperial’s plea of guilty in his re‑arraignment valid under the procedural safeguards ...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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