G.R. No. 110272 August 30, 1994
People of the Philippines vs. Jayson Diadid y Aglubat, Cozette Aragon y Timonel, and Rainier Lisbog y Pampag

FACTS

Accused Jayson Diadid, Rainier Lisbog, Cozette Aragon, and Reyderick Lago (at large) were charged with Robbery with Homicide. The prosecution alleged that on July 24, 1991, they conspired to enter the house of Benjamin Raymundo in Mandaluyong by removing a jalousie blade. Once inside, they stole cash and jewelry. On the occasion of the robbery, they stabbed Raymundo multiple times, causing his death. Witness Rosanna Capacillo saw Lisbog leaving the victim’s compound carrying a bag. Ramon Bernardo, who visited the house that morning, encountered a young man inside who gestured that the victim was asleep. The police recovered part of the stolen jewelry and a blood-stained kitchen knife from the scene.
The defense presented a different narrative. Diadid and Lisbog claimed they were elsewhere during the incident. Diadid specifically alleged he was at a friend’s house. Cozette Aragon, however, pleaded guilty to the charge. The trial court convicted all three accused, sentencing Diadid and Lisbog to reclusion perpetua and Aragon, due to his minority and plea, to a lesser penalty. Only Diadid appealed his conviction.

ISSUE

The core issue is whether the guilt of accused-appellant Jayson Diadid for the crime of Robbery with Homicide was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed Diadid’s conviction but modified his penalty. The Court found the evidence sufficient to establish conspiracy. The collective actions of the accused—forcibly entering the house, killing the occupant, and carting away property—demonstrated a unity of purpose and design. The testimony of Cozette Aragon, who pleaded guilty and implicated his co-accused, was deemed admissible against Diadid. As a co-conspirator, Aragon’s extrajudicial confession, made after the conspiracy had ended, is admissible against his co-conspirators as a recognized exception to the hearsay rule, provided there is independent evidence of the conspiracy’s existence, which the prosecution established.
However, the Court applied privileged mitigating circumstances in favor of Diadid. At the time of the crime, he was over 15 but under 18 years old, entitling him to a penalty one degree lower than that prescribed by law. The penalty for Robbery with Homicide is reclusion perpetua to death; one degree lower is reclusion temporal. Furthermore, the ordinary mitigating circumstance of voluntary surrender was present, with no aggravating circumstance to offset it. Consequently, the penalty was reduced to reclusion temporal in its minimum period. Applying the Indeterminate Sentence Law, Diadid was sentenced to an indeterminate penalty of eight years and one day of prision mayor as minimum to fourteen years and eight months of reclusion temporal as maximum.