G.R. No. L-51256 August 12, 1986
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDITO PETENIA y RODA, CARLO CASTAÑEDA y SANTIAGO, defendants-appellants.

FACTS

The accused, Edito Petenia and Carlo Castaneda, along with a co-accused Romeo Lugon, were employees of Bonifacia Guanlao. They conspired to rob and kill her. On May 1, 1978, in Quezon City, Petenia and Lugon attacked Guanlao inside her bag factory, killing her by hitting her head with adobe stones. Simultaneously, Castaneda entered the victim’s house, cut the telephone wire, and stole her handbag containing cash and valuables. The trio then used the victim’s vehicle to flee, eventually dividing the loot in Eastern Samar before separating to hide in different provinces.
The appellants were later arrested in Masbate and Sorsogon, respectively. Upon arrest, items belonging to the victim were recovered from Castaneda. Both appellants gave extrajudicial confessions admitting their participation in the crime. They were charged and convicted by the Circuit Criminal Court of Robbery with Homicide and sentenced to death.

ISSUE

The primary issues were: (1) the admissibility and validity of the appellants’ extrajudicial confessions; (2) the existence of conspiracy; and (3) the applicability of the exempting circumstance of uncontrollable fear.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua due to the lack of necessary votes for the death penalty. On the first issue, the Court found it unnecessary to rule definitively on the constitutional infirmities of the extrajudicial confessions. The guilt of the appellants was proven beyond reasonable doubt by independent evidence, including their own admissions during trial, the circumstances of their arrest, and the recovery of the victim’s belongings from Castaneda. This evidence corroborated the essential facts of the crime.
Regarding conspiracy, the Court held it was sufficiently established. The appellants, together with Lugon, planned the crime two days prior. Their actions on the day of the crime—the simultaneous attack on the victim and the ransacking of her house—demonstrated concerted efforts towards the common felonious purpose of robbery and killing, indicating closeness of personal association and concurrence of sentiment.
Finally, the Court rejected the defense of uncontrollable fear. Petenia testified he participated out of fear of being hit with hollow blocks, not a knife, and Castaneda claimed a knife was poked at him. The Court found these claims incredible. Petenia admitted no knife was present, and Castaneda had multiple opportunities to escape, especially when he was alone in the victim’s house, but he did not. The requisites for the exempting circumstance—real, imminent, and uncontrollable fear of a greater injury—were not met. The trial court’s factual findings were upheld.