People v. Mojica
REITERATIONFacts
The Antecedents: On March 24, 1959, Gabriel Buclating, a leader of the "OXO gang," was stabbed to death by members of the "Sigue-sigue gang" inside the New Bilibid Prisons. Two hours later, in retaliation, Ruperto Artus, a prisoner and member of the "Sigue-sigue gang," was stabbed to death in Cell No. 1 of Dormitory No. 3-C of the same prison. Immediately after the stabbing of Artus, prisoners Nicolas Mojica (appellant) and Primitivo Ala offered to surrender to prison guard Jose Magkalas. They were ordered to discard the weapons used, an ice-pick and a flat, pointed instrument. Both Mojica and Ala had blood on their clothes and hands. Mojica was holding the flat, pointed instrument when he offered to surrender. Both admitted to stabbing and killing Artus. Their confessions were taken in writing and sworn to before the Assistant Director of Prisons. Procedural History: The Court of First Instance of Rizal found appellant Nicolas Mojica guilty of murder and sentenced him to death. Primitivo Ala pleaded guilty and was also sentenced to death, a sentence affirmed by the Supreme Court in G.R. No. L-15633. The Petition: This case is a review of the judgment of the Court of First Instance of Rizal finding appellant Nicolas Mojica guilty of murder.
Issue(s)
Whether the extrajudicial confession of appellant Nicolas Mojica was voluntarily made and sufficiently corroborated. Whether conspiracy attended the commission of the crime. Whether evident premeditation and treachery were present, qualifying the killing to murder. Whether the penalty of death is appropriate given the circumstances.
Ruling
The judgment of the Court of First Instance of Rizal finding appellant Nicolas Mojica guilty of murder and sentencing him to death is affirmed.
Ratio Decidendi
On the voluntariness and corroboration of the extrajudicial confession: The Court found substantial evidence corroborating Mojica's extrajudicial confession. The murder weapon he described was the same one he was seen holding and subsequently discarded. His confession detailed stabbing the deceased on the sides and stomach, consistent with the autopsy findings. The confession's narration of his co-accused's participation was also corroborated by the prison guard's testimony. The confession was sworn to before the Assistant Director of Prisons, creating a presumption of voluntariness, and Mojica failed to identify his alleged coercers. His explanation for the blood on his hands was unconvincing and contradicted by his co-accused's statement. On the presence of conspiracy: The Court found that conspiracy attended the commission of the crime, as evidenced by the extrajudicial confessions of both appellant Mojica and his co-accused Primitivo Ala. Both confessions stated that they had agreed to kill the deceased Artus to avenge the death of a leader of the "OXO gang." This mutual agreement to commit the crime established conspiracy. On evident premeditation and treachery: The Court held that evident premeditation was present, as there was ample evidence of how and why the crime was planned, with sufficient time intervening between its inception and execution. The decision to kill Artus was made immediately after learning of the death of their leader. Treachery was also found to be present, as the attack was sudden and insured the death of the victim, who was stabbed multiple times in vital parts while merely standing inside the cell. On the appropriateness of the death penalty: Considering that Mojica's co-accused, Primitivo Ala, was sentenced to death despite a judicial confession (which is a mitigating circumstance), and given the established conspiracy and the fact that the crime was committed while the accused was serving sentence, the Court concluded that the extreme penalty of death was necessarily in order.
Main Doctrine
An extrajudicial confession, even if admitted, requires substantial evidence to corroborate its claims, particularly concerning the identity of perpetrators and the circumstances of the crime. The presence of blood on the accused's clothes and hands, coupled with the recovery of the murder weapon as described in the confession, can serve as corroborating evidence. Furthermore, the voluntariness of a confession is presumed when it is sworn to before a public officer, and claims of coercion must be substantiated with credible evidence.