GR 106537; (July, 1993) (Digest)
G.R. No. 106537 July 27, 1993
PEOPLE OF THE PHILIPPINES, petitioners, vs. ARNEL ORACOY and NILO PLARISAN (AT LARGE), accused, ARNEL ORACOY, accused-appellant.
FACTS
The lifeless body of Joel Vailoces, a helper at the Equatorial Security Agency owned by Santiago Sierra, was found in Sierra’s farm in Sitio Tagaytay, Pardo, Cebu. Written on the deceased’s left palm in blue ballpen were the words: “Arnel Oracoy, bata-bata.” Two shotguns belonging to the agency were missing. Police investigators, led by this clue, proceeded to the house of Arnel Oracoy, a former employee of Sierra who was dismissed for mishandling fighting cocks, and invited him to the police station. There, Oracoy executed an extrajudicial confession admitting to the crime and identifying Nilo Plarisan as his co-conspirator. He led the police to a cave where the two stolen shotguns were recovered. Oracoy and Plarisan were charged with Robbery with Homicide. Oracoy pleaded not guilty, while Plarisan remained at large. The trial court found Oracoy guilty beyond reasonable doubt and sentenced him to reclusion perpetua. Oracoy appealed, arguing the trial court erred in relying on circumstantial evidence, in admitting his extrajudicial confession allegedly obtained through force and without proper Miranda warnings and counsel, and in not acquitting him.
ISSUE
The main issues are: (1) Whether the circumstantial evidence is sufficient to convict; (2) Whether the extrajudicial confession is admissible; and (3) Whether the accused should be acquitted.
RULING
The Supreme Court affirmed the trial court’s decision, finding Oracoy guilty beyond reasonable doubt. The Court held that the totality of the circumstantial evidence—Oracoy’s presence in Cebu City near the crime scene on the fateful day, his name written on the victim’s palm (which he failed to explain), and the recovery of the stolen shotguns based on his information—pointed to his guilt. The Court found the extrajudicial confession admissible, noting it was given with the assistance of a PAO lawyer, Atty. Nelson Pañares, who testified that he informed Oracoy of his rights. The Court gave weight to the trial court’s assessment of witness credibility and found the defense of alibi weak and unconvincing. The conviction for Robbery with Homicide was upheld.