Case Summary (G.R. No. 240084)
Background of the Case
On September 19, 1980, the Circuit Criminal Court of Cebu City found Comendador guilty of robbery with homicide, sentencing him to death and requiring him to indemnify the heirs of Jungie Zaragosa in the amount of P12,625.00. The court’s verdict was primarily based on Comendador’s plea of guilty and his extrajudicial confession, supported by circumstantial evidence from several witnesses.
Evidence Presented at Trial
The prosecution presented witness testimonies that established a sequence of events leading to the crime. Testimony from Edilberto Zaragosa confirmed that his son, Jungie, was accompanied by Comendador, who had previously expressed his concern about Jungie's safety in Cebu. Dolores Reponte identified both men as they passed her on the day of the incident, and Angelo Obenque testified that Comendador arrived at his home later that day with items belonging to the victim, including the victim's watch.
Law Enforcement's Role
Police Corporal Dioscoro Panda-an provided critical testimony regarding the discovery of Jungie's body, detailing how he secured the crime scene and found evidence such as the murder weapon and items belonging to the victim. Lieutenant Edilberto Evangelista later apprehended Comendador, who admitted to the killing and surrendered incriminating evidence.
The Confession
Upon being interrogated, Comendador signed an extrajudicial confession, wherein he detailed the events of the crime. It was noted in court that he was advised of his rights, though the confession's admissibility was challenged due to the absence of legal counsel at the time it was given. Despite this challenge, the court upheld the confession's validity based on the circumstances surrounding its acquisition.
Appellate Considerations
In reviewing the trial court’s judgment, the Supreme Court addressed several points of contention raised by Comendador. This included arguments about his plea being conditional, the admissibility of the confession, sufficiency of evidence, and the presence of aggravating circumstances.
Analysis of the Plea and Confession
The Court reaffirmed that a plea of guilty is typically indisputable evidence of guilt. It ruled that Comendador's conditional request for a lesser penalty did not alter the nature of his guilty plea, which was deemed unconditional and spontaneous. Even if the extrajudicial confession was deemed inadmissible due to constitutional concerns, the Court maintained that the guilty plea, coupled with corroborating circumstantial evidence, adequately proved Comendador's guilt beyond reasonable doubt.
Aggravating Circumstances
The trial court found several aggravating circumstances, including craft, uninhabited place, and
...continue readingCase Syllabus (G.R. No. 240084)
Case Summary
- The case involves Diosdado Comendador, who was found guilty beyond a reasonable doubt of robbery with homicide and sentenced to death by the Circuit Criminal Court in Cebu City.
- The accused's guilt was primarily established through his plea of guilty, an extrajudicial confession, and several testimonies presented during the trial.
- The court ordered Comendador to indemnify the heirs of the victim, Jungie Zaragosa, in the amount of P625.00 for unrecovered property and P12,000.00 as indemnity.
Background of the Case
- The incident occurred on October 25, 1973, when the victim, Jungie Zaragosa, was killed.
- Edilberto Zaragosa, the father of the deceased, testified that the accused was an acquaintance and had advised his son to travel to Cebu for safety.
- The victim was last seen with the accused before his body was discovered in Toledo City.
Evidence Presented
- Testimonies of Witnesses:
- Edilberto Zaragosa: Father of the victim, testified about the victim's travel plans and the financial assistance he provided.
- Dolores Reponte: Witnessed the accused and the victim together shortly before the murder.
- Angelo Obenque: Noted suspicious behavior of the accused after the crime, including possession of the victim's belongings.
- Dioscoro Panda-an: Police corporal who investigated the scene and found evidence related to the crime.
- Edilberto Evangelista: Police lieutenant who took the accused into custody and obtained an admission of guilt.
- Gabriel Trocio