People v. Alberca

G.R. No. 117106 (June 26, 1996)

Facts:

On April 11, 1994, in Quezon City, the accused-appellant, Jimmy Alberca, along with several unidentified accomplices, entered the compound of Pastor and Rebecca Saycon with the intent to commit robbery. During the incident, they attacked Felipe Climaco, a security guard, and Joey Rodriguez, a houseboy. Climaco was stabbed multiple times and later died from his injuries, while Rodriguez sustained a stab wound but survived. The group also stole Climaco's service firearm, a .38 caliber revolver.

The attack began when Climaco, alerted by the intruders, attempted to retrieve his firearm. He was shot and subsequently stabbed by the assailants. Rodriguez, who was awakened by the commotion, tried to assist Climaco but was also attacked. After the incident, the police found one of the intruders, Diego Aruta, dead in the garden, having been shot during the confrontation.

Alberca was arrested on April 17, 1994, and subsequently gave an extrajudicial confession to the National Bureau of Investigation (NBI), detailing the plan to rob the Saycon residence, which he claimed was conceived by his accomplices. He described how the group executed the robbery and the violence that ensued. However, he later claimed that his confession was coerced and that he was threatened into signing it.

The trial court found Alberca guilty of robbery with homicide and physical injuries, sentencing him to death and ordering him to pay indemnities to the victims' heirs and the security agency.

Legal Issues:

1. Whether the extrajudicial confession of the accused-appellant was admissible in evidence.
2. Whether the trial court erred in giving credence to the prosecution's witnesses while disregarding the defense's evidence.
3. Whether the evidence presented was sufficient to prove the accused-appellant's guilt beyond a reasonable doubt.
4. Whether the penalty of death was appropriate given the circumstances of the case.

Arguments:

Prosecution:

• The prosecution argued that the extrajudicial confession was valid as it was made voluntarily after the accused was informed of his rights. They presented testimonies from witnesses, including Joey Rodriguez, who positively identified Alberca as one of the attackers.
• The prosecution contended that the evidence, including the confession and the circumstances surrounding the crime, established a clear case of conspiracy and intent to commit robbery with homicide.

Defense:

• The defense contended that the extrajudicial confession was inadmissible as it was obtained under duress and without proper legal counsel. Alberca claimed he was threatened and that the lawyer present was not his counsel of choice.
• The defense also presented an alibi, asserting that Alberca was in San Miguel, Bulacan, at the time of the crime, and argued that the prosecution's evidence was insufficient to establish his guilt beyond a reasonable doubt.

Court's Decision and Legal Reasoning:

The Supreme Court upheld the trial court's decision, affirming Alberca's conviction for robbery with homicide. The Court found that:

1. The extrajudicial confession was admissible as Alberca was informed of his rights and voluntarily waived them. The presence of his wife and the assigned counsel during the confession further supported the validity of the waiver.
2. The positive identification of Alberca by Rodriguez, coupled with the circumstantial evidence, was sufficient to establish his presence at the crime scene and his involvement in the attack.
3. The Court clarified that the crime committed was robbery with homicide, as the taking of the firearm occurred during the commission of the violent act, satisfying the legal definition of the complex crime.
4. The Court noted that while the trial court imposed the death penalty, there was insufficient evidence to classify the group as a "syndicated crime group" under the law. Therefore, the penalty was modified to reclusion perpetua.

Significant Legal Principles Established:

• The case reaffirmed the standards for the admissibility of extrajudicial confessions, emphasizing the necessity of informing the accused of their rights and ensuring that any waiver of those rights is made voluntarily and intelligently.
• It clarified the legal interpretation of robbery with homicide, establishing that the intent to rob does not need to be the sole motive for the homicide to qualify as a complex crime.
• The distinction between conspiracy and organized crime was highlighted, indicating that mere conspiracy does not automatically elevate the crime to that of a syndicate.