Case Summary (G.R. No. 163756)
Facts
The case stems from an incident on January 30, 1987, involving the robbery and double homicide of two household helpers in the home of Jose Macalino in Makati. Patrol officers conducting a routine inspection apprehended Oscar Robles and Antonio Manas, who were passengers in a taxicab. Upon questioning, Robles confessed to participating in the robbery, revealing that items taken from the Macalino residence were found in their possession. The police subsequently discovered the victims' bodies at the crime scene, corroborating the allegations against the accused.
Charges and Proceedings
Robles and Manas were charged with Robbery with Double Homicide. The prosecution's case included the extrajudicial confessions of both defendants, where they implicated each other in the homicide. The trial proceeded with both accused insisting they had not participated in the murders, leading to an eventual guilty verdict for conspiracy to commit the robbery with homicide based on established evidence.
Legal Arguments
Robles contended that his extrajudicial confession should be deemed inadmissible due to alleged coercion and lack of effective assistance of counsel. He also argued that circumstantial evidence was insufficient to establish his guilt. The prosecution, however, maintained that the confessions were valid and substantiated by surrounding circumstances and physical evidence obtained at the scene.
Decision on the Admissibility of Evidence
The court held that the extrajudicial confessions were admissible, supported by the presence of counsel during the investigation and trial. The trial court noted that Robles did not raise any claims of intimidation at the time the confessions were made. The evidence against him included corroborating testimony and physical evidence linking him to the crime, which collectively established his involvement.
Circumstantial Evidence and Conviction
The court found sufficient circumstantial evidence to uphold Robles's conviction. The evidence suggested that he was complicit in the robbery as a lookout and participated in the looting. Important to note was the principle that when homicide occurs during a robbery, all participants in the crime can be charged as principals, even if they did not directly commit the act of killing.
Sentencing
Robles was sentenced to reclusion perpetua, with the court affirming this penalty while increasing the indemnity to the vic
...continue readingCase Syllabus (G.R. No. 163756)
Case Background
- The case involves an appeal by Oscar Robles y Moana against a decision made by the Regional Trial Court of Makati, Branch 148, regarding Criminal Case No. 28829.
- The court's decision, dated March 30, 1989, convicted Robles and his co-accused, Antonio Manas y Flava, of the crime of Robbery with Homicide, sentencing them to reclusion perpetua and ordering them to pay the heirs of the victims P30,000.00 as indemnity.
- Vicente Antonio y Haya, the third accused, remains at large, and only Robles is the subject of this appeal since Manas did not contest the ruling.
Incident Overview
- On January 30, 1987, at approximately 1:00 P.M., police officers Rey Cocson, Edgar Amurao, and C. Tabanera were patrolling Del Pan Street, Tondo, Manila.
- The officers signaled a taxicab with two male passengers, identified later as Manas and Robles, for a routine inspection due to their suspicious behavior.
- Robles confessed to the police that they had robbed the house of Jose Macalino in Makati, while Manas remained silent during the initial questioning.
- A police search revealed a .38 caliber revolver on Robles and a balisong (fan knife) on Manas, along with stolen items in bags found in the taxi.
Discovery of the Crime
- Detective Ernesto Gatpayat, upon investigating the crime scene at Jose Macalino’s residence, discovered two deceased individuals, Marilou Dalugdugan and Diego Limato, identified as household helpers.
- A screwdriver was found next to Dalugdugan's body, indicating a violent struggle.
Statements and Confessions
- After being informed of their rights, Robles admitted to participating in the robbery but denied involvement in the killings.
- He claimed he acted as a lookout while Manas entered the h