G.R. No. L-30169 February 16, 1982
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CRISPIN FLORES Y DECAÑENTA, defendant-appellant.

FACTS

Accused Crispin Flores was charged with robbery with homicide for the killing of Ernesto Lam on September 24, 1968, in Manila. The information alleged that Flores, conspiring with two others, robbed the victim of a revolver and a wristwatch and, on the occasion thereof, stabbed him to death. After trial, the Circuit Criminal Court found Flores guilty and imposed the death penalty, appreciating the aggravating circumstance of abuse of superior strength. The case was elevated to the Supreme Court for automatic review.
The prosecution evidence established that the victim was found mortally wounded and stated he was robbed before dying. A taxi driver, David Escalderon, testified he drove two men, including the accused, to the scene and saw them arguing with the victim moments before the incident. The accused later gave a detailed extrajudicial confession admitting his participation, stating he stabbed the victim when he resisted, while his two companions took the watch and gun. The defense contested the confession’s voluntariness and argued the evidence was insufficient to prove conspiracy and the aggravating circumstance.

ISSUE

The primary issue is whether the trial court erred in convicting the accused of robbery with homicide and in appreciating the aggravating circumstance of abuse of superior strength to justify the death penalty.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s finding that the accused’s extrajudicial confession was voluntary, as it was given with the assistance of counsel and without evidence of coercion. This confession, corroborated by the taxi driver’s testimony placing the accused at the crime scene and the victim’s ante-mortem statement, sufficiently established his guilt for robbery with homicide. The taking of personal property was integral to the killing, satisfying the elements of the complex crime.
However, the Court eliminated the aggravating circumstance of abuse of superior strength. The prosecution failed to prove that the accused and his cohorts cooperated to secure advantage from their superior strength or that they were physically stronger than the victim. The mere fact that there were three assailants is insufficient to constitute this aggravating circumstance, especially since the evidence indicated only the accused inflicted the fatal wound. With no other aggravating or mitigating circumstances attending the crime, the proper penalty is reclusion perpetua. The Court thus modified the sentence from death to reclusion perpetua while affirming the civil indemnities.