GR 80042; (March, 1990) (Digest)
G.R. No. 80042. March 28, 1990.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ADOLFO QUIÑONES, RONILO CANABA, AMADO CONDA, JR., ZALDY CIVICO and ALFREDO ABAN, accused-appellants.
FACTS
On June 30, 1986, the decomposing bodies of Alexander Sy, Augusto Gabo, and Frisco Marcellana, bearing multiple wounds, were discovered in Basud, Camarines Norte. The accused-appellants were charged with robbery with multiple homicide. The prosecution evidence established that on the evening of June 27 or 28, 1986, the appellants blocked the victims’ car on the Maharlika Highway using sacks, abducted the three men, robbed them (including Sy’s cash and valuables totaling P330,000.00), killed them in a wooded area, and fled using the stolen vehicle. The case heavily relied on the extra-judicial confessions of Quiñones and Canaba, given with the assistance of counsel, which detailed their participation. At trial, Quiñones affirmed his confession, making it judicial. Civico, whose initial extra-judicial confession was without counsel, later validly affirmed it in court with assistance of counsel. Conda’s extra-judicial confession, given without counsel, was correctly rejected by the trial court.
ISSUE
Whether the trial court correctly convicted the appellants and whether the penalty imposed for the killing of three persons during a robbery was proper.
RULING
The Supreme Court affirmed the conviction but modified the penalty. The legal logic is twofold. First, on the admissibility of confessions, the Court upheld the validity of the confessions of Quiñones and Canaba as they were assisted by counsel. For Civico, his initial uncounselled confession was inadmissible, but he subsequently purged its defect by freely affirming it on the witness stand with the assistance of his counsel, thereby converting it into a valid judicial confession. These confessions, corroborated by other evidence, sufficiently established guilt.
Second, and crucially, the Court corrected the legal characterization of the crime. The appellants were incorrectly charged and sentenced for “robbery with multiple homicide.” The Revised Penal Code only prescribes the special complex crime of “robbery with homicide” under Article 294. This crime is a single, indivisible offense regardless of the number of persons killed, provided the killings were by reason or on the occasion of the robbery. Following precedent (People v. Cabuena), the multiple killings are merged into the composite crime. Therefore, only one penalty of reclusion perpetua should be imposed on each appellant, not multiple life terms. Furthermore, since reclusion perpetua is a single indivisible penalty, the discussion of aggravating or mitigating circumstances by the trial court was unnecessary under Article 63 of the Revised Penal Code. The civil indemnity was set at P30,000.00 for each victim’s heirs, with an additional P330,000.00 awarded to Sy’s heirs for the stolen property.