GR 37507; (June, 1977) (Digest)
G.R. No. L-37507. June 7, 1977.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILLIAM PAGE, defendant-appellant.
FACTS
The case originated from a jeepney holdup on February 13, 1972, along Roxas Boulevard. Appellant William Page, then an 18-year-old student, and his companion Crisanto Camposano, armed with a knife and a revolver, held up the driver and passengers, including Randolf Scot and sisters Veronica Villaverde-Balacapo and Cesarea Villaverde. During the robbery, the female passengers were forced out of the moving vehicle. Veronica Balacapo died from her injuries. Page was later arrested, and he executed a detailed confession admitting his participation in the robbery, though he later repudiated it at trial, claiming innocence. The trial court convicted Page of robbery with homicide based largely on this extrajudicial confession and the testimony of victim Randolf Scot, who identified Camposano but was less certain about Page’s direct involvement.
ISSUE
The core issue is whether the trial court erred in convicting Page of robbery with homicide based on his repudiated extrajudicial confession and the evidence presented, despite his claim of non-involvement and alleged lack of positive identification.
RULING
The Supreme Court affirmed the conviction. The legal logic rests on the admissibility and credibility of Page’s extrajudicial confession. The Court found that the confession was voluntarily executed, as it was taken with the assistance of counsel and sworn before a municipal judge, satisfying the requirements for admissibility. The confession contained detailed facts about the crime that only a participant would know, lending it credibility and indicia of reliability. Furthermore, the Court applied the doctrine of conspiracy. Even if Page did not personally inflict the fatal injuries on the victim, his conscious participation in the armed robbery made him equally liable as a co-principal for the resulting homicide under Article 294(1) of the Revised Penal Code. The killing was a foreseeable consequence of the violent robbery they jointly undertook. The Court rejected appeals for leniency, noting Page’s subsequent criminal behavior, including an escape attempt, and emphasized the need for retributive justice to deter crimes in public conveyances. The judgment was modified only to include restitution for the stolen items.