G.R. No. L‑3093
FACTS
– On 6 May 1904 Regino Manabat entered the house of Feliciana Puri in Concepcion, Tarlac, in darkness, assaulted her with his revolver, and forced her to hand over ₱6.50. He fled after firing a shot through a window.
– The only identification of the accused was by the victim’s recognition of his voice, given their long acquaintance.
– Manabat was arrested the next day, detained until Monday, and before a Justice of the Peace signed a written confession admitting guilt.
– At trial he withdrew the confession, asserted that it was made under duress, and presented three alibi witnesses. The alibi testimonies were contradictory and deemed unreliable.
– The trial court convicted Manabat of robbery (Art. 503, §5, Penal Code) and sentenced him to 3 years 8 months 1 day imprisonment, with restitution of ₱6.50.
ISSUE
Whether the trial court’s conviction and sentence should be affirmed, considering the reliance on a withdrawn confession and the contested alibi evidence.
RULING
– The Court held that, despite the exclusion of the written confession, the victim’s testimony was sufficient to establish guilt beyond reasonable doubt.
– The alibi was rejected due to material contradictions among the witnesses.
– The trial court failed to consider aggravating circumstances; committing robbery at night and exploiting darkness warrants the maximum penalty.
– Accordingly, the conviction was affirmed, but the sentence was altered to the maximum period for the offense: six (6) years, ten (10) months, and one (1) day of imprisonment (presidio mayor), with the accessory penalties, restitution of ₱6.50 (with subsidiary imprisonment if insolvent), and payment of costs of both instances.
The judgment was ordered to be entered after ten days, followed by remand to the lower court for execution.