G.R. No. L-69667 July 26, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ERNESTO JOCSON y MARIANO, ROMEO BASILIO y CRISOSTOMO, ALFREDO SANTOS y ROBLES, & REYNALDO CALAYAG y SABILUNA, accused-appellants.

FACTS

Appellants Ernesto Jocson, Romeo Basilio, Alfredo Santos, and Reynaldo Calayag were charged with Robbery with Homicide. The information alleged that on April 15, 1983, in Balanga, Bataan, the four conspired to rob the house of Victor Cimatu. By means of violence and intimidation, they stabbed and killed Cimatu and his bodyguard, Eugenio Andres, and carted away various personal properties and cash. After a plea of not guilty, the accused, during trial, changed their plea to guilty. The trial court, following jurisprudence, did not immediately convict but required the prosecution to present additional evidence to establish aggravating circumstances and the degree of culpability.
The prosecution evidence established that Jocson, a former employee of victim Cimatu, masterminded the robbery. He met with his co-accused, and they agreed to rob Cimatu. The group proceeded to the victim’s residence, where Jocson and Basilio stabbed the victims while Santos and Calayag helped subdue them. They then ransacked the house, stole properties, and fled using Cimatu’s car. The stolen items were later recovered after Calayag led the police to them. All accused executed extrajudicial confessions detailing their roles.

ISSUE

Whether the trial court erred in convicting appellant Ernesto Jocson of Robbery with Homicide based on the evidence presented, notwithstanding his plea of guilty and the alleged procedural irregularities.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the propriety of the trial court’s procedure after a guilty plea in a capital offense. The Court held that the trial court correctly did not rely solely on the plea of guilty. Following established jurisprudence, the court properly required the prosecution to present additional evidence to prove the crime’s specifics and any aggravating circumstances. This safeguarded the accused’s rights and ensured the plea was informed and voluntary.
The evidence, independent of the extrajudicial confessions (whose admissibility was not relied upon), overwhelmingly established Jocson’s guilt. His leadership role was clear from the testimonial and circumstantial evidence, including the recovery of stolen items traced through his co-accused. The defense claim of Jocson’s alleged mental illness was rejected as unsupported by the trial record, where he was competently assisted by counsel who never raised the issue. Under Article 294(1) of the Revised Penal Code, the penalty for Robbery with Homicide is reclusion perpetua to death. With the abolition of the death penalty under the 1987 Constitution , the only imposable penalty is reclusion perpetua, an indivisible penalty where modifying circumstances are immaterial. Thus, the Court modified the penalty from death to reclusion perpetua and affirmed the civil liabilities.