Title
People vs. Escober y Geralde
Case
G.R. No. 69564
Decision Date
Jan 29, 1988
Two security guards conspired in a robbery at a supply store, resulting in the fatal stabbing of two children; convicted of robbery with homicide, sentenced to life imprisonment.

Case Summary (G.R. No. 69564)

Key Dates

Crime occurred on December 3, 1982. Original information filed December 9, 1982; arraignments in March–April 1983. Trial court decision rendered January 10, 1984. Supreme Court judgment on consolidated appeals issued January 29, 1988.

Applicable Law and Doctrines

Primary substantive provision: Article 294 (Robbery with Homicide) and related provisions of the Revised Penal Code (e.g., Article 17, par. 3 — principals by indispensable cooperation; Article 296 — band). Constitutional and procedural issues were measured against the applicable constitutional guarantees invoked in the records (including requirements under Section 9, Article X of the 1973 Constitution regarding form and content of court decisions and provisions protecting the right to counsel and against compelled self‑incrimination as reflected in the investigation transcripts and prefatory warnings).

Procedural Posture

Two consolidated matters reached the Supreme Court: G.R. No. 69564 (automatic review of death sentences) and G.R. No. 69658 (petition for certiorari by Escober seeking to expedite review). The trial court found both Escober and Punzalan guilty of robbery with homicide, sentenced both to death and awarded damages. The Supreme Court reviewed the trial record and evidence; it set aside the trial court’s judgment and rendered judgment disposing of both accused.

Prosecution’s Case — Factual Summary

Prosecution alleged a conspiracy led by Amadeo Abuyen/Roberto Alorte with five companions. The group allegedly entered the Bee Seng premises, robbed VICENTE Chua of P5,000 from an office drawer and, on the occasion of the robbery, inflicted multiple stab wounds on two children (Irvin, 13; Tiffany, 6), who later died. Evidence included testimony of the Chuas, security personnel, police investigation sketches and exhibits (including a blood‑stained scissor blade), witness statements identifying Punzalan at the gate, Punzalan’s written extra‑judicial statement (Exhibit M) purporting to admit participation, and later extrajudicial admissions attributed to Abuyen (Exhibit B).

Defenses Presented

Escober testified that he was the security guard on duty, that Abuyen (a former co‑guard) and companions forced him at gunpoint into the pickup, took his service firearm from the locker, and that after the robbers left he called for assistance and cooperated with police. He denied knowing or participating in any conspiracy. Punzalan testified he had been invited by Abuyen for drinks, accompanied them to the compound, waited outside, later observed blood on the other men as they fled and was fetched into a taxi; he denied personal participation in the killings and later claimed his custodial statement was coerced by physical ill‑treatment and electric shock.

Trial Court Decision — Form and Substance

The trial court’s decision (1½ single‑spaced pages) concluded both accused were guilty as principals by indispensable cooperation and imposed death sentences plus damages. The decision stated the court found the material allegations proved and listed some factual pointers and aggravating circumstances, but did not specifically articulate the testimonial or documentary evidence relied upon or analyze how each asserted fact was established. The Supreme Court found that the trial court’s opinion failed to meet the constitutional requirement that a court’s decision “clearly and distinctly state the facts and the law on which it is based,” citing earlier precedents and emphasizing the necessity that findings of fact be particularized to allow meaningful appellate review.

Supreme Court’s Remedial Approach on Decision Defect

Although the constitutional defect ordinarily requires remand for rendition of a new judgment, the Supreme Court elected to resolve the matter on the merits because the record, transcripts and all evidence necessary for adjudication were before the Court. The Court nonetheless condemned the trial court’s broadly stated conclusions and its failure to itemize the evidence supporting specific findings.

Analysis and Ruling on Juan Escober — Acquittal

The Court thoroughly reviewed the evidence relating to Escober and concluded his guilt was not proved beyond reasonable doubt. Key points of that analysis:

  • Opening the gate to a person known to the guard (Abuyen) was, by itself, an innocuous or at most negligent act; proof of an evil intent beyond reasonable doubt was required but lacking.
  • The prosecution’s suggestion that a gunshot was a ritual staged to exculpate Escober was implausible; firing at a co‑conspirator is an unreliable and dangerous contrivance and the gunshot could reasonably have been directed at or intended to frighten others.
  • Extrajudicial statements of alleged co‑conspirators (Punzalan’s preliminary statement and Abuyen’s extrajudicial confession) tended to support Escober’s version that Abuyen fired at him; although co‑conspirator statements are “polluted,” the spontaneous and corroborative nature of those statements undermined the prosecution theory.
  • The only direct testimony placing Escober near Abuyen after the shot was Mrs. Lina Chua’s observation. The Court found reasons to question accuracy given her agitated condition and inconsistencies in descriptions; that testimony was not sufficient, when taken with the remainder of the record, to prove conspiracy and culpable participation to the required degree.
  • The Court reiterated the fundamental criminal law principle that presence at the scene or suspicious circumstances alone cannot displace the presumption of innocence: the prosecution must prove criminal design and participation as clearly and convincingly as the crime itself.

Accordingly, the Supreme Court acquitted Juan Escober of robbery with homicide and ordered his release unless held for other offenses.

Analysis and Ruling on Macario Punzalan, Jr. — Conviction

The Supreme Court found the evidence established beyond reasonable doubt that Punzalan knowingly participated in the conspiracy to commit robbery and acted as lookout. Key facets of the Court’s reasoning:

  • Punzalan admitted being fetched and going with Abuyen’s group and testified he waited outside the premises; evidence showed he left with the group when they fled.
  • Fleeing with accomplices and failure to report or to disclose involvement after the events (including when seeing reports in the press) supported knowledge of the plan.
  • The Court applied the well‑established doctrine that when a homicide occurs in the course of a robbery, all those who took part as principals in the robbery are principals in the special complex crime of robbery with homicide, even if they did not personally commit the killing, unless they clearly evidenced efforts to prevent the homicide.
  • The Court held Punzalan was a principal in the robbery and therefore guilty of robbery with homicide, noting the absence of any showing he tried to prevent the killings.

Punzalan’s extra‑judicial statement was held inadmissible insofar as the Court found that the police’s advisement of rights to him (given his low education) was superficial and misleading, particularly regarding the scope and timing of appointment of counsel; the waiver could not be regarded as intelligently made. Nevertheless, the Supreme Court concluded that the trial record contained sufficient other evidence to convict Punzalan despite the inadmissibility of the confession.

Remedies and Sentences

The Supreme Court set aside the trial court decision. It ordered immediate release of Juan Escober. It found Macario Punzalan, Jr. guilty beyond reasonable doubt of the complex crime of robbery with homicide and sentenced him to reclusion perpetua (the Court applied the abolition of the death penalty in the post‑constitutional context) and ordered indemnity to the heirs of the victims in the amount of P60,000.00.

Treatment of Damages and Trial Irregularities

The Court addressed procedural complaints: Punzalan’s claim of denial of counsel during custodial investigation, preliminary investigation and trial was examined. The Court found that police advisements were mechanically administered and that the waiver was not valid given misleading phrasing and Punzalan’s educational background; hence his extrajudicial confession was inadmissible. However, absence of counsel at preliminary investigation is a defect better raised and remedied below; such irregularity does not necessarily vitiate the information or deprive the court of jurisdiction and, absent showing of prejudice or bias in court‑appointed counsel, did not mandate dismissal. The Court found no prejudice caused by th

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