GR 88451; (September, 1991) (Digest)
G.R. No. 88451 September 5, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RONALD ALVAREZ y CRUZ, LEOPOLDO SABERON y CALUBAQUIB, and CHRISTOPHER ARANETA @ TOPPER, accused-appellants.
FACTS
The body of Ismael Magpantay with multiple stab wounds was discovered in a Valenzuela cemetery. An anonymous tip implicated appellants Ronald Alvarez, Leopoldo Saberon, and Christopher Araneta. Based on this information and after a conversation with Alvarez’s father, a former policeman, police officers arrested Alvarez and Saberon without a warrant at the Alvarez residence; Araneta was arrested separately. During investigation, Alvarez executed a sworn confession with the assistance of counsel, detailing the conspiracy to kill the victim due to a dispute over proceeds from a robbery. He admitted being present but claimed he merely acted as a lookout, while Saberon and Araneta carried out the stabbing. All three were charged with and convicted of Murder.
ISSUE
The core issues are: (1) the validity of the warrantless arrests; (2) the admissibility and sufficiency of Alvarez’s extrajudicial confession to establish conspiracy; and (3) the correctness of the penalty imposed.
RULING
The Supreme Court affirmed the conviction but modified the penalty. The warrantless arrests were valid under Rule 113, Section 6 of the 1964 Rules of Court. A crime had in fact been committed, and the arresting officers, acting on the specific tip and the initiative of Alvarez’s father—a former policeman who had observed the appellants’ conduct—had reasonable ground to believe the appellants committed it. Alvarez’s extrajudicial confession was admissible as it was executed voluntarily with counsel present. His detailed account established conspiracy among the three, making each liable as a principal. His claim of being a mere lookout is immaterial; in conspiracy, the act of one is the act of all. However, the trial court erred in sentencing each appellant to “life imprisonment three (3) times.” Only one penalty is imposable for the single crime of Murder. The proper term is reclusion perpetua, not life imprisonment. Each appellant was thus sentenced to a single penalty of reclusion perpetua and ordered to pay jointly and severally P50,000.00 as civil indemnity.