Primary Holding

The Supreme Court affirmed the conviction but modified it to robbery under the Revised Penal Code, reducing the penalty, while rejecting retroactive application of 1987 constitutional safeguards on custodial investigations.

Background

Filoteo, accused of leading a syndicate of police and military personnel in hijacking a postal van, challenged his Sandiganbayan conviction. The case centered on constitutional rights during custodial investigations, retroactivity of constitutional guarantees, and the distinction between brigandage and robbery.

Facts

• 1. A postal delivery van was hijacked on MacArthur Highway by armed individuals using a Mercedes Benz. Victims identified suspects, leading to Filoteo’s arrest. He confessed to orchestrating the crime, implicating co-accused. Checks were recovered via his assistance. Filoteo later alleged torture and invalid waiver of rights.

Arguments of the Petitioners

• 1. Confession was coerced through torture and obtained without counsel.
• 2. Arrest was illegal (no warrant).
• 3. Prosecution evidence insufficient for brigandage; crime was robbery.
• 4. Alibi and lack of direct eyewitness identification.

Arguments of the Respondents

• 1. Confession was voluntary, with proper waiver under 1973 Constitution.
• 2. Arrest valid as part of standard operations.
• 3. Evidence (confession, seized checks, witness IDs) proved guilt.
• 4. Crime qualified as brigandage under PD 532 due to highway location and armed coordination.

Issues

• 1. Admissibility of Filoteo’s uncounselled 1982 confession.
• 2. Whether torture invalidated the confession.
• 3. Validity of warrantless arrest.
• 4. Sufficiency of evidence for conviction.
• 5. Proper crime classification (brigandage vs. robbery).

Ruling

• 1. Confession Valid: 1973 Constitution applied prospectively; Morales vs. Enrile (1983) safeguards did not retroactively invalidate 1982 waiver.
• 2. No Torture: Medical reports and signature consistency disproved coercion claims.
• 3. Arrest Valid: Failure to challenge arrest pre-trial waived objections.
• 4. Sufficient Evidence: Confession, checks, and witness IDs proved robbery.
• 5. Reclassified Crime: Hijacking was a single robbery, not organized brigandage under PD 532. Penalty reduced under Revised Penal Code.

Rationale

• 1. Prospectivity of Judicial Decisions: Constitutional protections (e.g., counsel during waiver) apply prospectively.
• 2. Admissibility of Confessions: Voluntary confessions under 1973 rules remain valid.
• 3. Presumption from Possession: Unexplained possession of stolen goods implies theft.

Key Excerpts

• 1. “Proof beyond reasonable doubt cannot be equated with substantial evidence.” (On burden of proof).
• 2. “The rule of prospectivity... ensures reliance on the law at the time of the act.” (On retroactivity).

Precedents Cited

• 1. Morales vs. Enrile (1983): Established custodial rights under the 1973 Constitution.
• 2. People vs. Luvendino (1992): Confirmed prospective application of waiver rules.
• 3. People vs. Puno (1993): Distinguished isolated robbery from brigandage.

Statutory and Constitutional Provisions

• 1. 1973 Constitution, Art. IV, Sec. 20: Rights during custodial investigations.
• 2. 1987 Constitution, Art. III, Sec. 12: Non-retroactive requirement for counsel during waiver.
• 3. Revised Penal Code Arts. 293–295: Robbery penalties.
• 4. PD 532 (Anti-Piracy and Anti-Highway Robbery Law): Misapplied by Sandiganbayan.