People

vs. Camat
April 2, 1996| Regalado, J. | Co-conspirators Statements
PETITIONER: People of the Philippines
RESPONDENT: Armando Rodriguez Camat (aka Amboy Camat) and Wilfredo Tanyag Del Rosario (aka Willie)

SUMMARY: Camat and Del Rosario were charged with the complex crime of robbery with homicide and frustrated homicide
for robbing and stabbing/attempting to kill Penalver and for killing Sinoy. During the police investigation, the police
investigator testified on the witness stand that Camat admitted that Del Rosario was a co-conspirator in the crime. SC held
that even though the Court could not convict Del Rosario based on Camats extra-judicial confession, there are other pieces
of evidence sufficient to sustain a conviction (i.e. Penalvers testimony).

DOCTRINE: SEE RATIO NO. 2.

FACTS:

1. Armando Rodriguez Camat (aka Amboy Camat) and the crime, and that the electric tester they stole from
Wilfredo Tanyag Del Rosario (aka Willie) were charged with Penalver can be recovered from his relatives.
the complex crime of robbery with homicide and frustrated That they were able to identify Camat with the help of
homicide. a vendor who witnessed the incident, and said
Nelson Sinoy and Gonzalo Penalver are members of witness identified Camat as the one who killed Sinoy.
the Philippine Marines. They were walking along
Quirino Avenue when they noticed 2 men trailing 4. The lower court found both Camat and Del Rosario guilty
them closely. of the crime of robbery with homicide and frustrated
Sinoy and Penalver crossed the street to avoid the homicide.
men following them, but Del Rosario rushed to
Sinoy, and kicked the latter while Camat followed 5. Appellants now argue that the trial court cannot reply
Del Rosario and stabbed Sinoy. solely on Camats extrajudicial confession as a basis of their
Penalver kicked Camat, who in turn, stabbed the conviction because it was obtained during custodial
former. When Penalver fell to the ground, Del investigation, in violation of their constitutional rights.
Rosario grabbed the clutch bag.
Sinoy and Penalver, despite their injuries, ran away ISSUES:
and were brought by a policeman to the hospital. 1. W/N their constitutional rights were violated NO.
Sinoy died in the hospital, but Penalver survived. 2. W/N Camats admission is binding on Del Rosario
NO.
2. Camat and Del Rosario interposed the defense of alibi. 3. W/N evidence is sufficient to support a conviction
Camat claimed that he was already in his house, and YES.
before going home, he worked as a card dealer in the 4. W/N the appellants were deprived of their right of
saklaan. This was corroborated by his mother-in- confrontation when the prosecution failed to produce
law, who claimed she was with Camat at the time the the informer who allegedly pointed to/identified Camat
latter was at home. NO.
Del Rosario claimed that he was with his wife during
the time the crime was committed, and they sold RULING: CA affirmed.
vegetables along a sidewalk of Quirino Ave. in
Baclaran. Upon going home, he claimed that he never RATIO:
left the house again. His mother supported his story. 1. The lower court cannot just rely on the testimony o Camat
Both claimed they did not know each other prior to because there is no showing that the appellants were duly
the date of the commission of the crime. advised of the mandatory guarantees under the Bill of Rights.

3. Patrolman Odeo Cario, to whom the case was assigned, 2. No reliance can be placed on the imputation therein
testified on the following: because it violates the rule on res inter alios acta (a thing
That Camat orally admitted to him their participation done between others does not harm or benefit others) and
in the killing of the soldiers. Cario also testified that does not fall under the exceptions thereto, especially since it
Camat gave the names of Del Rosario and a certain was made after the supposed homicidal conspiracy. An
person named Roland as his co-conspirators in the extrajudicial confession is binding only upon the
crime charged. confessant and is not admissible against his co-accused.
That Camat admitted that Del Rosario was the one As against the latter, the confession is hearsay.
who actually stabbed Sinoy.
That when he and another policeman traced the 3. The testimony of a single witness, if found convincing and
whereabouts of Del Rosario and brought him for trustworthy by the trial court, is sufficient to support a
questioning, Del Rosario admitted his involvement in finding of guilt beyond reasonable doubt.
 this case are the mother and mother-in-law, who are
Penalvers testimony was found to be categorical and candid, naturally expected to make statements in his favor. The
untainted by inconsistencies, contradictions or evasions. It positive identification of the malefactors made by Penalver
creditably chronicles the material details in the commission negates appllants submissions on their respective alibis.
of the crimes in question, and should accordingly be given
full credence. 4. The accuseds constitutional right to meet the witnesses
face to face is limited to proceedings before the trial court.
There was also no evidence of any ulterior or evil motive on Accordingly, appellants reliance upon this constitutional
the part of Penalver that might have led him to give right is misplaced as the same is available to him at the trial
fabricated testimony against the appellants. He, and even and not during a custodial investigation.
Camat, declared in open court that they did not know each
other before the incident. And where there is no evidence It is the prerogative of each party to choose its own
indicating that the principal witness for the prosecution was witnesses in accordance with its own assessment of the
moved by improper motive, the presumption is that he was evidence it needs to prove its case. If appellants felt that the
not so moved, and his testimony is entitled to full faith and vendor might have a grudge against Camat, there was
credit. nothing to prevent them from determining that fact on the
witness stand by calling said vendor via compulsory process
The appellants alibis could not also be given credence even if available to them both under the Constitution and the Rules
they are corroborated by other witnesses. The witnesses in of Court.