G.R. No. L-33957. March 15, 1984.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JAIME SOLIS, ARSENIO MANCHOS and BERNARDITO KINTANAR, Accused-Appellants.

FACTS

The case involves the automatic review of a death penalty imposed by the Court of First Instance of Sorsogon for the crime of Robbery with Homicide. The victim, Herminio Corsita, was found dead in the yard of his house on July 28, 1968, with a gaping wound and signs of struggle. Police investigation revealed his house had been forcibly entered, a locker and trunk were ransacked, and bloodstained weapons, including a bolo and pieces of wood, were found at the scene. Initially, the police had no eyewitnesses and their first suspects were cleared. The investigation was revived months later upon receipt of anonymous letters pointing to the perpetrators residing in Sitio Nasohi.
Acting on this tip, police apprehended Bernardito Kintanar first on February 6, 1969, believing he would be the most likely to confess. Following Kintanar’s arrest and extrajudicial confession implicating his co-accused, Jaime Solis and Arsenio Manchos were subsequently arrested. All three appellants executed sworn confessions before the Municipal Judge, admitting their participation in the robbery and detailing how Solis killed Corsita when the victim resisted. During trial, the prosecution presented these confessions and the circumstantial evidence. The accused, assisted by their counsel, waived their right to present evidence, submitting the case for decision based on the prosecution’s evidence.

ISSUE

Whether the trial court erred in convicting the appellants of Robbery with Homicide based on their extrajudicial confessions and circumstantial evidence, despite the absence of eyewitnesses and alleged irregularities in their arrest and legal representation.

RULING

The Supreme Court affirmed the conviction but reduced the penalty to reclusion perpetua due to lack of the necessary votes for execution. The legal logic is clear. First, the appellants’ extrajudicial confessions were deemed admissible and voluntary. They were executed with the assistance of counsel and after being properly informed of their constitutional rights. The confessions were corroborated by the physical evidence found at the crime scene, which was consistent with the narrative of a robbery and killing. The Court rejected the claim of defective counsel, noting that the appellants were represented throughout the proceedings without objection, and counsel’s failure to present evidence was a tactical decision following their clients’ waiver.
Second, the appellants’ failure to present any exculpatory evidence at trial, despite having the opportunity, weakened their defense. The Court cited the principle that while an accused is not compelled to testify, the risk of an unfavorable inference arises from the non-production of evidence when the prosecution’s evidence strongly points to guilt. Here, the mass of circumstantial evidence and the detailed confessions established guilt beyond reasonable doubt. Finally, on the nature of liability, the Court applied the well-settled doctrine that all participants in a robbery are liable as principals for a homicide committed on the occasion thereof, unless they endeavored to prevent it. The appellants’ admitted participation in the robbery made them collectively liable for the resulting death. The civil indemnity was increased to P30,000.00.