People v. Gorospe
REITERATIONFacts
1. The Antecedents: The defendants, Ruperto Gorospe and Lorenzo Gorospe, were charged with the crime of murder for allegedly intentionally, illegally, and criminally taking the life of Joaquin Reyes on or about November 29, 1906, with treachery and known premeditation. 2. Procedural History: The defendants were arrested, arraigned, and pleaded not guilty. The lower court found both defendants guilty as accessories to the crime of homicide, sentencing each to two years, four months, and one day of prision correccional, with accessory penalties, indemnity to the heirs of the deceased, and costs. The defendant Lorenzo Gorospe appealed this sentence. 3. The Petition: The appeal was based on the sole evidence presented in the lower court: alleged extrajudicial confessions. The appellant argued, and the Attorney-General recommended, that these confessions should not have been admitted without proof of voluntariness. The Supreme Court, upon review, agreed that the judgment of the lower court should be reversed and the defendant discharged.
Issue(s)
Whether the extrajudicial confessions of the defendants were admissible in evidence without proof of their voluntary nature. Whether the judgment of the lower court should be reversed based on the inadmissibility of the evidence.
Ruling
The judgment of the lower court was reversed, and the defendant Lorenzo Gorospe was ordered to be discharged from custody, unless held on some other charge, with costs of both instances de oficio.
Ratio Decidendi
On the admissibility of extrajudicial confessions: The Court held that the only evidence adduced during the trial was evidence of alleged extrajudicial confessions made by the defendants. These confessions should not have been admitted in evidence without first showing that they had been made voluntarily and without coercion. The Court cited Section 4 of Act No. 619 and previous cases, United States vs. Pascual and United States vs. De la Cruz, in support of this principle. The Attorney-General concurred with this view, recommending the discharge of the defendant based on the lack of proof of voluntariness. On the reversal of the lower court's judgment: Upon examination of the record, the Court was of the opinion and so held that the judgment of the lower court should be reversed. This reversal was a direct consequence of the finding that the sole basis for the conviction, the extrajudicial confessions, were inadmissible due to the failure to prove their voluntary execution. Consequently, the defendant Lorenzo Gorospe was ordered discharged from custody, as there was insufficient admissible evidence to sustain the conviction.
Main Doctrine
Extrajudicial confessions are inadmissible as evidence unless it is first proven that they were made voluntarily and without coercion.