People v. Camat

G.R. No. 112262 (April 2, 1996)

Facts:

Accused-appellants Armando Rodriguez Camat and Wilfredo Tanyag del Rosario were charged with the special complex crime of robbery with homicide and frustrated homicide in connection with an incident that occurred on September 1, 1985, in Parañaque, Metro Manila. The information filed against them alleged that they conspired to rob Gonzalo Penalver and Nelson Sinoy, using force and intimidation. During the robbery, they stabbed Sinoy, resulting in his death, and also stabbed Penalver, who survived due to timely medical assistance.

On the night of the incident, Sinoy and Penalver, both members of the Philippine Marines, were walking along Quirino Avenue after attending a birthday party. They noticed two men following them and attempted to avoid them by crossing the street. However, the accused approached them, with del Rosario kicking Sinoy and Camat stabbing him. Penalver intervened but was also stabbed by Camat. The assailants then took Penalver's clutch bag containing tools valued at P150.00.

Sinoy was taken to San Juan de Dios Hospital, where he died despite medical efforts. Penalver was also hospitalized for his injuries. The police investigation led to the arrest of Camat, who allegedly confessed to his involvement and named del Rosario as his accomplice. Del Rosario was later arrested and also confessed to his participation in the crime.

At trial, both accused pleaded not guilty and presented alibi defenses, claiming they were at home during the time of the incident. Their alibis were supported by family members. However, the prosecution relied on the testimony of Penalver, the surviving victim, and the extrajudicial confessions of both accused.

Legal Issues:

1. Whether the extrajudicial confessions of the accused were admissible in evidence given the alleged violation of their constitutional rights during custodial investigation.
2. Whether the prosecution's evidence, particularly the testimony of a single eyewitness, was sufficient to establish the guilt of the accused beyond reasonable doubt.
3. Whether the trial court erred in convicting the accused of both robbery with homicide and frustrated homicide, given the nature of the charges.

Arguments:

• For the Accused:

  • The accused argued that their extrajudicial confessions were obtained in violation of their constitutional rights, specifically the right to counsel and the right against self-incrimination. They contended that the confessions should be deemed inadmissible.
  • They maintained that the prosecution failed to prove their guilt beyond reasonable doubt, relying solely on the testimony of Penalver, which they claimed was not credible.
  • They asserted that the trial court erred in convicting them of both robbery with homicide and frustrated homicide, arguing that the latter charge was redundant.

• For the Prosecution:

  • The prosecution argued that the extrajudicial confessions were valid and admissible, as they were made voluntarily and corroborated by the circumstances of the crime.
  • They emphasized the credibility of Penalver's testimony, asserting that it was clear, consistent, and sufficient to establish the identity of the assailants and the events that transpired.
  • The prosecution contended that the charges were properly filed, as the law allows for the inclusion of multiple offenses arising from a single criminal act.

Court's Decision and Legal Reasoning:

The court ruled that the extrajudicial confessions of the accused were inadmissible due to the failure of law enforcement to inform them of their constitutional rights during custodial investigation. The court emphasized that any confession obtained in violation of these rights cannot be used against the accused, regardless of its truthfulness.

Despite the inadmissibility of the confessions, the court found that the prosecution had sufficiently established the guilt of the accused through the credible testimony of Penalver. The court noted that the testimony of a single eyewitness can be sufficient for conviction if it is found to be credible and trustworthy. The trial court's assessment of Penalver's demeanor and the absence of any motive to fabricate his testimony further supported the conviction.

Regarding the charges, the court clarified that the accused should only have been charged with robbery with homicide, as the concept of "homicide" in the context of robbery encompasses all acts resulting in death or serious injury. The court modified the judgment to reflect this legal principle, affirming the conviction for robbery with homicide and increasing the civil indemnity for the victim's heirs.

Significant Legal Principles Established:

1. The inadmissibility of confessions obtained in violation of constitutional rights during custodial investigation.
2. The sufficiency of a single eyewitness testimony to support a conviction if deemed credible.
3. The clarification that charges of robbery with homicide should not include separate counts for homicide and frustrated homicide, as the latter is absorbed in the former.