G.R. No. 71626 ; March 22, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SEVERINO CATUBIG y GOTIB @ “BOY”, ALBERTO RAGUINDIN y GARCIA @ “AMBET”, CRISPIN SARMIENTO y ROLLODA @ “ANGOT” and JOHN DOE @ “NORBERTO”, @ “FELIPE”, accused-appellants.

FACTS

Accused-appellants Severino Catubig, Alberto Raguindin, and Crispin Sarmiento, along with an unidentified companion, were charged with Robbery with Homicide. The prosecution alleged that on February 2, 1981, in Quezon City, the appellants, conspiring together, accosted Atty. Renato Flores and Engineer Ernesto Flores beside their parked taxicab. They announced a hold-up and, upon the victims’ refusal to surrender their valuables, mauled and stabbed the brothers to death. The appellants then took cash, jewelry, and personal items from the victims. After trial, the Regional Trial Court found the three appellants guilty beyond reasonable doubt and sentenced each to reclusion perpetua.
The appellants contested their conviction, arguing primarily that the prosecution’s evidence was weak and insufficient. Appellants Raguindin and Sarmiento specifically asserted that their extrajudicial confessions were inadmissible as they were executed without the assistance of counsel, violating their constitutional rights. All appellants generally claimed that the prosecution failed to prove their guilt beyond reasonable doubt.

ISSUE

The central issue is whether the prosecution proved the guilt of the appellants beyond reasonable doubt for the crime of Robbery with Homicide, notwithstanding the challenges to the admissibility of the extrajudicial confessions and the overall strength of the evidence.

RULING

The Supreme Court affirmed the conviction. The Court held that the guilt of the appellants was established beyond reasonable doubt by the collective weight of the evidence, independent of the contested extrajudicial confessions. The prosecution presented credible eyewitness testimony, specifically from a taxi driver who positively identified appellants Catubig and Raguindin at the crime scene and witnessed the assault. This direct testimony was corroborated by circumstantial evidence, including the appellants’ own admissions during the investigation that placed them at the location.
The Court emphasized that the constitutional requirement for counsel applies specifically to custodial investigations. The records did not sufficiently establish that Raguindin and Sarmiento were already under custodial investigation at the time they gave their statements to justify the exclusion of these confessions. Regardless, the positive identification by the eyewitness provided a solid basis for conviction. The defense of alibi proffered by the appellants was rightly rejected for being weak and unsubstantiated. The crime was duly qualified as Robbery with Homicide, as the killing was perpetrated by reason or on the occasion of the robbery. The Court modified the civil indemnity, increasing it to P50,000.00 for each victim, in line with prevailing jurisprudence.