GR 144086; (February, 2002) (Digest)
G.R. Nos. 144086-87; February 6, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDRALIN TABOGA, accused-appellant.
FACTS
Accused-appellant Edralin Taboga was charged with Robbery with Homicide and Arson for the death of septuagenarian Francisca Tubon. In the early morning of April 1, 1998, her house in Magsingal, Ilocos Sur was set ablaze. Her charred remains were discovered inside, bearing stab wounds. Personal belongings, including rings and a necklace, and a sack of rice were found scattered near the scene. Barangay officials noticed fresh bloodstains on Taboga’s shorts. When confronted, he orally admitted to the killing and arson. This admission was later repeated to a radio announcer. Forensic analysis showed the blood on his shorts and a recovered knife matched the victim’s Type O blood.
Taboga interposed the defense of denial and alibi, claiming he was asleep at a nearby house and only helped douse the fire. He argued his extrajudicial confession was inadmissible as it was not reduced to writing and signed. The trial court convicted him of both crimes, sentencing him to death for Robbery with Homicide and an indeterminate penalty for Arson, and ordered him to pay damages.
ISSUE
The core issue is whether the prosecution proved Taboga’s guilt beyond reasonable doubt for the complex crime of Robbery with Homicide and for Arson.
RULING
The Supreme Court affirmed the conviction but modified the penalties. The Court found the totality of circumstantial evidence sufficient to establish guilt. The bloodstains on Taboga’s clothing, scientifically linked to the victim, placed him at the crime scene. His spontaneous oral confessions to the barangay captain and the radio announcer, made prior to any police custody and without coercion, were admissible as voluntary admissions. His denial and alibi could not prevail over this positive evidence. The Court ruled the crimes were separate acts. The robbery and killing constituted the special complex crime of Robbery with Homicide. The subsequent act of setting the house on fire to conceal the body was a distinct crime of Arson. The death penalty for Robbery with Homicide was reduced to reclusion perpetua, as the qualifying circumstance of dwelling was not alleged in the Information. The Court affirmed the award of civil indemnity, moral damages, and actual damages for funeral expenses, but deleted the award for the value of the burned house for lack of sufficient proof.