GR 123147; (October, 2000) (Digest)
G.R. No. 123147 ; October 13, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSEPH MANENG y ORTESA, accused-appellant.
FACTS
On March 16, 1993, a robbery and double homicide occurred at the residence of Alfredo Gelito in Valenzuela. His housekeepers, Hermosa Gelito and Nenita Santiago, were found dead, and cash, jewelry, and other valuables were missing. Investigation led the police to suspect Joseph Maneng. On March 18, 1993, he was apprehended at the Batangas port while attempting to board a ferry to Mindoro. A search revealed a necklace with a heart-shaped pendant in his possession. At the police station, after being apprised of his constitutional rights in the presence of his counsel de oficio from the Public Attorney’s Office, Maneng executed a sworn statement detailing his participation in the crime alongside two companions.
At trial, the prosecution presented Maneng’s extrajudicial confession, wherein he admitted to the robbery and described the rape and killing of the two victims. The defense presented an alibi, claiming Maneng was at work as a welder during the incident and was only at the port to visit his family. He alleged that his confession was coerced through physical violence by the police.
ISSUE
The core issue is whether the trial court correctly convicted the accused based on his extrajudicial confession, notwithstanding his claims of coercion and alibi.
RULING
The Supreme Court affirmed the conviction. The extrajudicial confession was deemed admissible as it was proven to be voluntary and made with the competent assistance of independent counsel, specifically a PAO lawyer. The Court found the detailed narration within the confession, which included facts known only to the perpetrator, to be indicative of its voluntariness and reliability. The defense of alibi was properly rejected as it could not prevail over the positive evidence of the confession. The crime was correctly classified as the complex crime of robbery with homicide, as the killings were committed on the occasion of the robbery. The penalty of reclusion perpetua was affirmed, as the crime was committed prior to the reimposition of the death penalty under Republic Act No. 7659 . The Court modified the damages, awarding an additional P10,000.00 as exemplary damages to the heirs of each victim due to the presence of the aggravating circumstance of multiple homicide.