G.R. No. 132601 - Echegaray vs. Secretary of Justice

An Amended Information for Robbery with Double Homicide was filed on September 1, 1992 against appellant Decena Masinag Vda. de Ramos and several co-accused, including Cesar Osabel.
The accusatory portion charged that on July 17, 1992, in Lucena City, the accused, armed with bladed weapons, robbed the Jael spouses of personal property and, concurrently, inflicted multiple stab wounds resulting in their deaths.
Upon arraignment, appellant Masinag pleaded "not guilty" leading to trial on the merits.

The crime involved the stealing of various items (e.g., solid gold ring, diamond ring, necklace, cash, samsonite bag, a .22 caliber firearm, a pair of sandals, a karaoke machine, an adidas jacket, and a pair of shoes) with a total value amounting to P67,800.00.
In addition to the robbery, it was alleged that the accused, using violence and intimidation, tied the victims’ hands and repeatedly stabbed them.
Medical evidence indicated that the victims died from massive shock secondary to hemorrhage and multiple stab wounds, with time of death established through post-mortem findings.

Activities preceding the incident, including a meeting at appellant’s residence on July 15, 1992, where conversations about the planned robbery allegedly took place among certain conspirators.
Events at the Jael spouses’ residence: evidence of sounds, a woman’s cry for help, and the subsequent discovery of bloodstains leading to the victims’ bodies.
His account of instructions given by Osabel and subsequent actions related to money obtained from the robbery.

Osabel’s initial extrajudicial confession implicating Masinag as a conspirator.
Later recantation by Osabel in open court, claiming his earlier statement was made under duress.

Testimony of a neighbor, Simeon Tabor, who discovered the victims’ bodies following unusual circumstances on the morning of July 17, 1992.
Medical and forensic reports by Dr. Vicente F. Martinez which provided the estimated time of death.

The Regional Trial Court of Lucena City, Branch 60, in Criminal Case No. 92-387, found appellant Masinag and Cesar Osabel guilty beyond reasonable doubt of Robbery with Homicide.
Accused who were found lacking sufficient evidence (Isagani Guittap, Wilfrido Morelos, and Luisito Guilling) were acquitted.
The trial court also imposed indemnification orders against the convicted for civil damages to the heirs of the deceased victims.

Appellant argued that she did not actively participate in the conspiracy or the actual commission of the crime.
It was contended that the extrajudicial confessions presented were either hearsay or insufficient as they were not supported by independent evidence establishing her overt participation or involvement in the planning.
The defense emphasized that allegations based on hearsay, particularly statements relayed by state witness Dador through Osabel, should not be used to bind her under the principles of res inter alios acta.

Whether the trial court committed a reversible error by finding appellant Masinag guilty beyond reasonable doubt of conspiring with her co-accused to commit Robbery with Homicide despite the absence of any independent evidence of her active participation.
Whether the extrajudicial confessions of Osabel and Dador, which were based on hearsay and not derived from their own personal knowledge, can be reliably used to establish appellant’s complicity in the conspiracy.
The application and admissibility of evidence under Rule 130, Section 36 of the Rules of Court, particularly in relation to hearsay and subsequent reliance on foreign declarations against a co-accused.