G.R. No. L-32661 July 20, 1982
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CESAR DE LA CRUZ alias “OSCAR”, accused-appellant.

FACTS

Accused-appellant Cesar de la Cruz, along with several others, was charged with robbery in band with rape. The incident occurred on May 12, 1963, in Pura, Tarlac, where armed men robbed Fernando Salazar’s house and, on the same occasion, raped Carmelita Salazar. After trial, the Court of First Instance convicted de la Cruz and co-accused Leonardo Altura of the complex crime and sentenced them to reclusion perpetua. Altura died during appeal. The Court of Appeals initially received the appeal but later certified it to the Supreme Court upon realizing the imposed penalty was within the latter’s exclusive jurisdiction.
The prosecution’s evidence included the testimony of victims and an extrajudicial confession from de la Cruz. The defense contested the confession’s admissibility, claiming it was obtained without informing him of his constitutional rights and through force and intimidation. The trial court and the appellate proceedings upheld the confession’s voluntariness, noting it was sworn before a municipal judge who attested that no signs of coercion were present on the accused.

ISSUE

The primary issue is whether the extrajudicial confession of the accused-appellant is admissible as evidence to sustain his conviction for the complex crime of robbery with rape.

RULING

The Supreme Court affirmed the conviction. The Court ruled that the extrajudicial confession was voluntarily given and admissible. The legal logic centered on the procedural safeguards observed at the time of the confession in 1964. The confession itself contained a preamble stating the appellant had been apprised of his constitutional rights, which he acknowledged before proceeding. While the specific rights were not detailed in the record, the Court held that the comprehensive Miranda warnings were not mandatory under Philippine law at that time. Furthermore, the 1973 Constitution’s provision embodying the Miranda doctrine has no retroactive effect and thus could not invalidate a confession obtained prior to its effectivity.
The Court found the confession credible and corroborated by other evidence, sufficiently establishing de la Cruz’s participation in the conspiracy to commit robbery. The rape was committed by a co-conspirator on the same occasion, making all conspirators liable for the complex crime under the principle of conspiracy. However, in view of the appellant’s age at the time of the crime (22) and his prolonged detention of over 18 years, the Court recommended him for executive clemency to the President. Justices Aquino and Barredo dissented, arguing the evidence showed conspiracy only for robbery, not rape.