GR L 40235; (February, 1985) (Digest)
G.R. No. L-40235 February 25, 1985
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOAQUIN SALBINO, ET AL., accused. SY CHIN and ANTONIO AGRAVANTE, accused-appellants.
FACTS
The case involves the robbery with homicide of Chan Seng. The prosecution evidence, primarily from the testimony of discharged state witness Cecile Barrameda and the extrajudicial confessions of co-accused Joaquin Salbino and appellant Antonio Agravante, established a conspiracy. Appellants Sy Chin, Agravante, and Salbino plotted the robbery in Sy Chin’s house, targeting Chan Seng who lived nearby and was believed to possess a large sum of money. In the early morning of October 16, 1969, Salbino and Agravante, armed with a knife and revolver, entered the victim’s residence. Salbino stabbed Chan Seng to death during the robbery, after which they took P400. The perpetrators then returned to Sy Chin’s house, delivered the money to him as planned, and subsequently fled. Sy Chin left for Manila that same morning.
ISSUE
The core issues are whether the guilt of Sy Chin as a co-conspirator was proven beyond reasonable doubt and whether Agravante’s extrajudicial confession is sufficiently corroborated by evidence of the corpus delicti.
RULING
The Supreme Court affirmed the conviction. The trial court’s exhaustive evaluation of the evidence correctly established conspiracy and guilt beyond reasonable doubt. The discharge of Barrameda as a state witness was proper, as his testimony was essential to prove Sy Chin’s role as a co-principal by inducement and the conspiracy between the young perpetrators and Sy Chin. His testimony corroborated the details of the planning and the division of the stolen money.
Regarding Agravante’s confession, the Court found it admissible and corroborated by independent evidence of the corpus delicti—the proven fact that a robbery and homicide occurred. The reenactment photos and other evidence consistently supported the confessions. The appellants’ alternative narrative, which sought to exonerate Agravante by blaming Salbino and another individual, was rightly rejected by the trial court as less credible than the coherent and corroborated evidence presented by the prosecution. The judgment was modified only by increasing the civil indemnity to P30,000.