G.R. No. 101335 ; June 8, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. OSCAR ROBLES Y MOANA, ANTONIO MANAS Y FLAVA, VICENTE ANTONIO Y HAYA, accused, OSCAR ROBLES Y MOANA, accused-appellant.

FACTS

On January 30, 1987, police officers on patrol in Tondo, Manila, flagged down a taxi for a routine inspection. The passengers, appellant Oscar Robles and co-accused Antonio Manas, acted suspiciously. The police found two bags containing various valuables. Upon questioning, Robles admitted they had just robbed a house in Makati belonging to Jose Macalino. A .38 caliber revolver was found on Robles and a fan knife on Manas. The police later contacted a family member using a nametag from the loot and proceeded to the Macalino residence, where they discovered the bodies of two household helpers, Marilou Dalugdugan and Diego Limato, and a ransacked house.
Robles, in his extrajudicial confession taken with counsel present, admitted participation in the robbery but denied involvement in the killings. He claimed he acted only as a lookout while Manas and another accomplice, Vicente Antonio (at large), entered the house and committed the murders. Manas, in his own confession, admitted stabbing Dalugdugan and implicated Robles as being inside the house during the crime. Both were charged with Robbery with Homicide. The trial court convicted them, sentencing them to reclusion perpetua. Only Robles appealed.

ISSUE

Whether the prosecution proved beyond reasonable doubt appellant Oscar Robles’s guilt for the complex crime of Robbery with Homicide.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found that Robles’s extrajudicial confession was admissible, having been given voluntarily with the assistance of counsel. While an extrajudicial confession alone is insufficient for conviction, it was corroborated by the corpus delicti—the established facts that a robbery occurred at the Macalino residence and two homicides were committed on the same occasion. The evidence, including the recovery of the stolen items from Robles and Manas immediately after the crime and their possession of weapons, constituted circumstantial evidence that met the required criteria for sufficiency. These circumstances, taken together, led to an inescapable conclusion of guilt beyond reasonable doubt.
The Court rejected Robles’s defense that he was merely a lookout, ruling that such participation still constituted direct involvement in the conspiracy to commit robbery. In crimes like Robbery with Homicide, all conspirators are liable for the homicide committed by any one of them during the robbery, even if the killing was not originally intended, as long as it was a foreseeable consequence of their collective criminal act. Robles’s presence and active participation in the criminal design made him equally liable for the complex crime. The penalty of reclusion perpetua was affirmed, with modifications to the civil indemnity and damages awarded.