G.R. No. L-32625 August 31, 1979
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. OSMUNDO CASTAÑEDA y ENCONTERO, BENEDICTO DE AUSEN @ DICK @ BENNY, and JUANITO RAGURO, defendants, OSMUNDO CASTAÑEDA y ENCONTERO and JUANITO RAGURO, defendants-appellants.

FACTS

On March 1, 1970, Edmundo Enriquez was robbed and killed in Pasay City. His wallet, wristwatch, ring, shirt, and shoes were taken. A deaf-mute witness, Teresita Nobello, reported the crime to the police. Initially, no arrests were made. Months later, appellant Osmundo Castañeda was arrested by the NBI. He executed a sworn extra-judicial confession detailing his participation and implicating his co-accused, Juanito Raguro and Benedicto de Ausen. Castañeda stated that after drinking with the victim, they lured him to a dark alley where Raguro struck the victim with a lead pipe and De Ausen stabbed him. Castañeda admitted to pushing the victim. The group then divided the stolen money.
Subsequently, Juanito Raguro was also arrested. He likewise executed an extra-judicial confession corroborating Castañeda’s account of the robbery and killing. Both appellants pleaded not guilty at trial. The prosecution presented their confessions and the testimony of eyewitness Teresita Nobello. The defense claimed the confessions were coerced, but the trial court found them voluntary and convicted Castañeda and Raguro of the complex crime of Robbery with Homicide, sentencing them to death. The case was automatically elevated to the Supreme Court for review.

ISSUE

The principal issue is whether appellants Castañeda and Raguro, who did not personally inflict the fatal wounds, can be held liable as principals for the complex crime of Robbery with Homicide.

RULING

Yes. The Supreme Court affirmed the conviction, applying the settled doctrine of conspiracy in the context of the complex crime of Robbery with Homicide. The Court meticulously examined the extra-judicial confessions and found them to be voluntarily given, detailed, and corroborative of each other, establishing a conspiracy among the accused to commit robbery. The legal logic is clear: when a homicide is committed as a consequence or on the occasion of a robbery, all those who conspired and participated as principals in the robbery are equally liable as principals of the entire complex crime. This liability attaches even if a particular conspirator did not actually deal the fatal blows.
The Court explicitly rejected the appellants’ reliance on an isolated, outdated precedent (People vs. Basistan) which suggested a contrary rule. It reinstated and followed the long-standing doctrine established in U.S. vs. Macalalad and consistently reiterated in subsequent cases like People vs. Bautista. The rule holds that all robbery conspirators are guilty of the resulting homicide unless there is clear, positive evidence that they attempted to prevent the killing. No such effort was shown here; the appellants’ active participation in the robbery scheme, which directly led to the murder, made them co-principals. The Court found no mitigating circumstances and affirmed the imposition of the death penalty, which was later commuted to reclusion perpetua following the constitutional abolition of the death penalty in 1987.