G.R. No. L-32508 & L-42104 April 28, 1980
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO CATINDIHAN, accused; THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO AGUJO and EDUARDO DURIA, accused.

FACTS

These consolidated cases involve separate trials for robbery with homicide stemming from the same incident on March 12, 1969, in San Miguel, Bulacan. Armed men entered the house of spouses Lorenzo Manuzon and Honorata Sevilla, took eighty pesos, and shot Honorata, who died the next day. Separate informations were filed as the accused were arrested at different times. Eduardo Catindihan was arrested in January 1970 and executed a detailed confession (Exh. B) before CIS agents, admitting participation and identifying his co-accused, including Eduardo Agujo as the shooter. At his trial, the prosecution presented this confession and the testimony of eyewitness Lorenzo Manuzon, who identified Catindihan. Catindihan repudiated his confession, claiming maltreatment, and pleaded an alibi.
In the joint trial of Eduardo Agujo and Eduardo Duria, the principal evidence included the extrajudicial confession of Agujo (Exh. T) and the sworn statement of the deceased witness Eduardo Dionisio (Exh. E). Agujo also repudiated his confession. Manuzon identified Agujo and Duria in a subsequent affidavit, though he had initially failed to identify Duria in a police lineup. Both Agujo and Duria were fugitives for a period.

ISSUE

The core issue is whether the guilt of Eduardo Catindihan, Eduardo Agujo, and Eduardo Duria for the crime of robbery with homicide was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the convictions. For Catindihan, the Court upheld the trial court’s finding that his extrajudicial confession was voluntary and admissible. The confession was replete with specific details, given by a literate individual in Tagalog, and sworn before an officer. His claim of maltreatment was unsubstantiated. The confession was corroborated by the corpus delicti—the established facts of the robbery and killing—and by the positive identification of eyewitness Lorenzo Manuzon. His alibi was correctly rejected as the distance between barrios did not preclude his presence at the crime scene, and his flight to Mariveles indicated guilt.
For Agujo and Duria, the Court found their culpability established. Agujo’s extrajudicial confession was deemed credible. While Dionisio’s sworn statement was hearsay as to them, it was partly corroborated by Agujo’s own confession. Manuzon’s subsequent affidavit positively identified them, curing his initial failure at the police lineup. Their status as fugitives from justice was considered an indication of guilt. The aggravating circumstances of band, dwelling, and nocturnity were properly appreciated. Consequently, the imposition of the death penalty for robbery with homicide under Article 294(1) of the Revised Penal Code was affirmed, with modifications regarding the solidary payment of indemnities.