G.R. No. L-56769 September 21, 1984
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARMOGENES SANCHEZ Y YAMSON, accused-appellant.

FACTS

Accused-appellant Armogenes Sanchez, then 16 years old, was charged with robbery with homicide for the killing of his employer, Ferdinand Mauri, inside a hardware store on June 30, 1979. The victim’s body, bearing two fatal stab wounds, was discovered two days later. A kitchen knife was found at the scene. Sanchez was arrested on September 3, 1979, and he executed an extrajudicial confession detailing the crime, including his motive stemming from being chided by the victim and his act of taking the victim’s wallet containing P150. He also reenacted the crime before police and the victim’s family.
The trial court convicted Sanchez of murder, sentencing him to reclusion perpetua, holding that the robbery was not proven. On appeal, Sanchez repudiated his confession, claiming it was coerced, and argued for the application of his alibi and entitlement to a suspended sentence due to his minority at the time of the crime.

ISSUE

The primary issues were: (1) the voluntariness and admissibility of Sanchez’s extrajudicial confession; (2) the correctness of his conviction for murder instead of robbery with homicide; and (3) his entitlement to a suspended sentence.

RULING

The Supreme Court affirmed the conviction but modified the crime and penalty. The extrajudicial confession was deemed voluntary and admissible. The Court found that Sanchez was properly informed of his constitutional rights, voluntarily waived them in writing, and the confession contained details only the perpetrator would know, corroborated by the medical evidence. His claim of maltreatment was unsupported, as he never complained to relatives or filed charges.
The trial court erred in not finding robbery. Sanchez’s own confession admitted taking the victim’s wallet and cash, which established the intent to rob. The complex crime of robbery with homicide exists even if the intent to rob is coupled with a desire for revenge, provided the intent to rob precedes the killing. Therefore, Sanchez is guilty of robbery with homicide as charged.
Regarding the penalty, Sanchez, being over 15 but under 18 at the time of the crime, was entitled to a one-degree reduction. The provisions on a suspended sentence were inapplicable as the crime is punishable by a penalty exceeding six years, and he was already over 18 when sentenced. The Court modified the penalty to an indeterminate sentence of seven years of prision mayor as minimum to fifteen years of reclusion temporal as maximum and increased the indemnity.