G.R. No. 94757 . February 7, 1992.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PILAR AMPARO PINZON, ENRICO VILLANUEVA and ORLANDO CABRERA, accused. ENRICO VILLANUEVA and ORLANDO CABRERA, accused-appellants.

FACTS

On February 8, 1988, Dolores Lugos returned to her Pasig home to find her daughter, Maria Estela Lugos, and househelp, Serafia Cruz, dead from multiple stab wounds. Jewelry valued at P93,000 was missing. Investigation revealed that on the morning of the crime, a woman, later identified as accused Pilar Amparo Pinzon, hired tricycle driver Albino Tero to go to Calawaan. En route, they met another tricycle carrying two men, who transferred to Tero’s vehicle. Tero identified one as accused Enrico Villanueva, whose pants had bloodstains he claimed were from a fight. The group was later seen near the crime scene.
The trial court convicted Villanueva and Orlando Cabrera of Robbery with Double Homicide but acquitted Pinzon. Cabrera contested his conviction, arguing his extrajudicial confession was inadmissible and that conspiracy was not proven, claiming he merely acted under Villanueva’s instructions.

ISSUE

The core issue is whether the conviction of accused-appellant Orlando Cabrera for Robbery with Double Homicide is valid despite his claims regarding his extrajudicial confession and the absence of direct proof of conspiracy.

RULING

The Supreme Court affirmed Cabrera’s conviction. The legal logic rests on two pillars: the sufficiency of circumstantial evidence and the established doctrine of conspiracy. First, the Court held that a conviction can be sustained solely on circumstantial evidence when it constitutes an unbroken chain leading to a fair and reasonable conclusion of guilt. Here, the circumstances—Cabrera’s presence with the group near the crime scene and time, the bloodstains, the missing jewelry, and the violent deaths—formed a cohesive chain pointing to his participation.
Second, the Court ruled that conspiracy was adequately proven by the collective acts of the accused before, during, and after the crime, demonstrating a common purpose to commit robbery and use lethal force. Cabrera’s claim of merely following instructions does not negate conspiracy; unity in execution is sufficient. Furthermore, while an extrajudicial confession is generally admissible only against its maker, it can serve as corroborative evidence of other facts establishing another accused’s guilt. Cabrera’s confession, in this context, corroborated the circumstantial evidence of his role. Consequently, as a conspirator, he is equally liable as a principal for the acts of his co-accused. The penalty of reclusion perpetua was affirmed, with civil indemnity increased to P50,000 for each victim’s heirs.