G.R. No. 122142 May 17, 2000
The People of the Philippines, plaintiff-appellee, vs. Jimmy Obrero y Corla, accused-appellant.

FACTS

Accused-appellant Jimmy Obrero was charged with robbery with homicide. The information alleged that on August 11, 1989, in Manila, he and an accomplice robbed Antonio Cabrera of P4,000.00 and, on the occasion thereof, killed Nena Berjuega and Remedios Hitta. The prosecution’s case hinged on an extrajudicial confession and witness statements. Pat. Benjamin Ines testified that appellant fled to Pangasinan after the incident and was later apprehended. He presented sworn statements from Helen Moral, who identified appellant as a regular delivery boy to the victims’ residence, and Anita De los Reyes, who claimed to have seen appellant fleeing the crime scene with bloodied hands. The prosecution also presented appellant’s extrajudicial confession, taken with the assistance of Atty. Bienvenido De los Reyes, wherein he admitted his participation.
The defense presented appellant and his sister, Merly Asuncion. Appellant denied the charges, claiming his confession was coerced through physical abuse and that he was not properly informed of his constitutional rights. He testified that he was merely forced to sign a pre-typed statement. His sister corroborated his claim of maltreatment, stating she saw his injuries after his arrest.

ISSUE

Whether the conviction of accused-appellant for robbery with homicide is valid based on the evidence presented by the prosecution.

RULING

No. The Supreme Court reversed the conviction and acquitted accused-appellant on the ground of reasonable doubt. The Court found the extrajudicial confession inadmissible as it failed to meet the stringent requirements for voluntariness under the Constitution. Atty. De los Reyes, who assisted during the custodial investigation, was not an independent counsel as he was also a PC Captain at the WPD Headquarters, creating a conflict of interest and failing to ensure the confession was freely given. The confession was thus obtained in violation of appellant’s right to counsel.
Furthermore, the other pieces of evidence were insufficient to sustain a conviction. The sworn statements of Helen Moral and Anita De los Reyes were inadmissible hearsay, as the witnesses themselves were not presented in court for cross-examination. Consequently, there was no competent evidence to identify appellant as the perpetrator. While the corpus delicti of the homicide was established, the element of robbery was proven solely by the inadmissible confession. The prosecution’s failure to present credible and admissible evidence created reasonable doubt. The Court emphasized the principle that it is better to acquit a guilty person than to convict an innocent one, and the procedural irregularities here warranted acquittal.