GR 39121 39122; (December, 1981) (Digest)
G.R. No. L-39121 and L-39122 December 19, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JACINTO PARCON, PRIMITIVO SABULAO, ARTEMIO LANGGAO, SUPERIANO ORAYAN and JULITO ORAYAN, accused. JULITO ORAYAN and SUPERIANO ORAYAN, accused-appellants.
FACTS
The case involves the robbery and killing of Eusebio Rosete and his two sons, Columbus and Hermogenes, in El Nido, Palawan, in April 1972. Eusebio was found dead in the sea near his farmhouse on April 7. His two sons were discovered decapitated in their residence on April 8. A robbery was evident as a trunk and a rice container were empty, and personal properties were missing. The accused-appellants, Superiano and Julito Orayan, were tenants of Eusebio. Their absence after the crimes and the recovery of stolen items, including cash and personal effects, from their possession upon arrest generated suspicion. The prosecution presented no eyewitnesses but relied heavily on the sworn extrajudicial statements of the appellants, wherein Superiano admitted to stabbing Eusebio and participating in the robbery, and Julito admitted involvement.
ISSUE
The primary issue is whether the extrajudicial confessions of the appellants, without corroborating eyewitness testimony, are sufficient to sustain their convictions for the complex crimes of robbery with homicide.
RULING
The Supreme Court affirmed the convictions but modified the penalties and the nature of Julito’s liability. The Court held that the extrajudicial statements, being declarations against penal interest and given voluntarily as attested by the police, are admissible and constitute strong evidence of guilt. For Superiano, his detailed confession provided the basis for his conviction. However, the Court reclassified the killing of Eusebio from a component of robbery with homicide to simple murder, as the evidence did not conclusively prove the robbery and homicide were a single continuous act. He was sentenced to reclusion perpetua for murder. For the killings of the two sons, the Court found him guilty of robbery with double homicide, also imposing reclusion perpetua after the death penalty was reduced due to lack of necessary votes.
For Julito, the Court found his participation did not rise to the level of a principal. His actions, including being present when the victims’ heads were disposed of and leaving with the co-accused, made him at least an accomplice in the robbery with double homicide. Considering he was a minor (14 years old) at the time of the crime but was over 24 at the time of judgment, he was entitled to a two-degree penalty reduction under the Revised Penal Code but not to a suspended sentence. His conviction for simple robbery was set aside, and he was sentenced as an accomplice to an indeterminate penalty. The Court also ordered indemnities to the victims’ heirs and the return of confiscated properties.