Title
People vs. Doble
Case
G.R. No. L-30028
Decision Date
May 31, 1982
A 1966 Navotas bank robbery involving homicides and assaults; appellants acquitted or convicted as accomplices, with reduced penalties due to limited roles.
A

Case Summary (G.R. No. L-30028)

Key Dates

Robbery and related killings: night of June 13–early morning of June 14, 1966.
Custodial interrogations and extra-judicial statements: June–July 1966 (as reflected in the record).
Trial court conviction and appeal: conviction imposed at trial; appellate review resulted in the judgment summarized below.

Applicable Law and Legal Framework

Constitutional context: At the time of the custodial interrogations (1966) the right to counsel during in-custody police interrogation had not yet been made a constitutional requirement; that protection was recognized under the 1973 Constitution, but was not applicable retroactively to the 1966 interrogations. The Court therefore assessed admissibility primarily under prevailing law and the established test of voluntariness.
Relevant penal law: Provisions of the Revised Penal Code discussed include Article 17 (principals), Article 18 (accomplices), Article 294 (robbery in band), Article 295 (penalty ranges for robbery in band), and Article 296 (relief from liability for assaults under certain circumstances). The Court applied established Philippine precedents cited in the record concerning voluntariness of confessions and distinctions between principals, accomplices, and conspirators.

Facts of the Offense as Found by the Trial Court

Ten men embarked by motor banca to Navotas intending to rob the Prudential Bank; eight disembarked for the operation. They used long guns, carbines and Thompsons; they fired shots and forcibly opened the vault, looted cash (P10,439.95 taken), and fled by banca. Several persons including peace officers and a market collector were killed; others were wounded. A police outpost beside the bank was fired upon and police personnel were among the casualties. Five accused were brought to trial; two (Mateo Raga and Celso Aquino) were acquitted at trial; three (Cresencio, Simeon, Antonio) were convicted by the trial court and sentenced to death.

Procedural History and Parties’ Positions on Appeal

The trial court imposed the death penalty on Cresencio Doble, Simeon Doble and Antonio Romaquin. On appeal, the Solicitor General recommended acquittal of Simeon Doble, and defended the voluntariness and admissibility of the extra-judicial statements of Cresencio and Antonio. Appellants contested the admissibility of their custodial statements on grounds of coercion, denial of counsel, and self-incrimination, and disputed the degree of their criminal liability (denying they were principals).

Court’s Assessment of Simeon Doble’s Liability

The Court accepted the Solicitor General’s recommendation and the record evidence that Simeon’s only connection was that the malefactors held a planning meeting at his house. Simeon’s testimony and custodial statement showed he did not participate in the operation, that he did not actively cooperate, that he had a five‑year-old foot injury precluding participation, and that he even told the malefactors he would wait at home. The Court applied the principle that mere knowledge, acquiescence, or passive presence without intentional cooperation or an act aiding the crime does not establish conspiratorial liability or make one a principal. On that basis the Court found the evidence insufficient to establish guilt beyond reasonable doubt and ordered Simeon Doble’s acquittal and immediate release unless held for other lawful causes.

Admissibility and Evaluation of Cresencio and Antonio’s Extra‑Judicial Statements

The appellants alleged physical coercion and involuntariness in the taking of their custodial statements (claims of punches, being struck with a gun butt, blindfolding/pepper causing blurred vision, and forced signing). The Court examined corroborating and disconfirming evidence: (a) the extra‑judicial statements of both appellants contained mutually fitting details about their respective roles (e.g., involvement with the banca), (b) one co-accused (Celso Aquino) gave statements and testified that no violence was used against him, (c) no medical certificates were presented to prove the alleged injuries, (d) Sgt. Lacson, the only named interrogator, denied the allegations of violence, and (e) the failure to secure the identities of the principal malefactors (the “John Does”) and the subsequent killing of a suspect did not show coercion at the time the principal statements were made. The Court applied the established Philippine test that voluntariness governs admissibility and noted that voluntariness is presumed but may be rebutted by proof of coercion; it found the appellants’ self-serving testimony insufficient to overcome the presumption of voluntariness. The Court therefore deemed the custodial statements admissible and properly considered in evaluating culpability.

Court’s Findings on Degree of Criminal Liability of Cresencio Doble and Antonio Romaquin

The Court concluded that the evidence did not establish that Cresencio and Antonio were co-principals by prior conspiracy or actual participation in the robbery and killings. Instead, the Court found they acted as accomplices: Cresencio accepted (or was asked to procure) a banca and assisted in bringing the banca and the malefactors to the scene; Romaquin provided the banca and received P441.00 (which the Court treated plausibly as rental or payment for cooperation). Additional indicia of culpable cooperation included a note from Cresencio to Romaquin urging concealment of names and Cresencio’s receipt of P41.00 from Romaquin. The Court emphasized that the banca was instrumental but not indispensable to the commission of the robbery (given the robbers’ armament and numbers), so the appellants’ cooperation, while knowing and intentional, was not indispensable to the crime’s execution. Consequently they were convicted as accomplices to robbery in band, not as principals responsible for homicide.

Sentencing and Civil Liability

For criminal liability as accomplices to robbery in band, the Court identified the applicable penalty as prision mayor (minimum to maximum range as provided in Article 295, considering aggravating circumstances of nighttime and use of a motorized banca). The Court imposed an indeterminate sentence for each appellant of from five years, four months, twenty-one days of prision correccional (minimum indeterminate term) to ei

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