People v. Estabillo
REITERATIONFacts
The Antecedents: Ambrosio and Roman Estabillo were charged with assassination. The information alleged that on the night of June 14, 1906, they, along with Isidro Leones, lay in wait for Leocadio Soriano, an Aglipayano priest. They followed him, and near the Aglipayano church in Pura, Tarlac, Ambrosio Estabillo seized Soriano by the throat, ordered his hands bound, and then struck him with a bolo multiple times, severing his head. They subsequently buried the body. Isidro Leones found a revolver on the deceased, which he gave to Roman Estabillo, who later admitted to burying it at Ambrosio Estabillo's order. The victim's headless body was found buried near where the head was discovered. Isidro Leones confessed to the crime, implicating the Estabillo brothers. The sergeant of police testified that Ambrosio Estabillo admitted to the killing due to resentment and betrayal. Roman Estabillo and Isidro Leones also made statements to the police detailing the events. The provincial fiscal testified that Ambrosio Estabillo admitted the allegations were true, stating the priest had dishonored him, and that Roman Estabillo and Isidro Leones aided him, but he wished to take full responsibility. Roman Estabillo also confessed to being present when Ambrosio and Isidro killed the priest. The justice of the peace testified that Ambrosio Estabillo admitted to the acts but would not plead guilty because the priest had dishonored him, and Roman Estabillo admitted to being with Isidro Leones when the offense was committed. Mateo Fernandez testified that Ambrosio Estabillo confessed to killing the priest and intended to kill his wife. Inocencio Marcelino heard Ambrosio Estabillo's voice warning his companions to keep quiet. Ambrosio Estabillo, then acting municipal president, directed the disinterment of the body under the pretense of burying a pig. Roman Estabillo admitted to burying the deceased's revolver in Ambrosio Estabillo's yard, where it was found. The accused denied the charges at trial, and Isidro Leones claimed his confession was due to maltreatment. The defense attempted to establish an alibi. Procedural History: The Court of First Instance found both appellants guilty of assassination and sentenced them to life imprisonment, accessory penalties, indemnification of P1,000, and costs. The Petition: The accused appealed their conviction.
Issue(s)
Whether the oral testimony of witnesses regarding the admissions and confessions made by the accused during the preliminary investigation and in conversations with officials is admissible in evidence. Whether the evidence presented, including confessions and corroborating circumstances, is sufficient to establish the guilt of the accused beyond a reasonable doubt.
Ruling
The judgment of conviction and the sentence of the trial court are affirmed.
Ratio Decidendi
On the admissibility of oral testimony regarding admissions and confessions: The Court held that oral testimony regarding admissions and confessions made by the accused during the preliminary investigation and in conversations with officials is admissible. The Court distinguished between statutory requirements for written examinations and the absence thereof in the Philippines under Act No. 194. Since there was no statutory mandate to reduce all statements of the accused to writing during preliminary investigations, and the accused did not testify under oath and subject to cross-examination, oral testimony was permissible. Furthermore, admissions made in casual conversations with officials, even if around the time of the preliminary investigation, are admissible as they are not part of the formal proceedings that must be reduced to writing. The Court also noted that the rule requiring written confessions typically applies to confessions made prior to or outside of the preliminary trial, and not to incidental statements made during the proceedings that were not reduced to writing. On the sufficiency of evidence to establish guilt beyond a reasonable doubt: The Court found that even excluding the extrajudicial confession of Isidro Leones (which was repudiated and not admissible against the accused) and the confession of Roman Estabillo to the sergeant of police (due to doubts about its voluntariness), there remained sufficient evidence from the voluntary admissions made by Ambrosio Estabillo to the justice of the peace, the provincial fiscal, and the president of the board of health. These admissions, coupled with the corroborative evidence establishing the corpus delicti (the discovery of the headless body and the circumstances of its burial), were sufficient to establish the guilt of both accused beyond a reasonable doubt. The Court found the defense of alibi unconvincing and noted that the inconsistencies in the prosecution's testimony were minor and did not cast doubt on the substantial accuracy of the witnesses' accounts.
Main Doctrine
Extrajudicial confessions, if properly admitted and corroborated by evidence of the corpus delicti, are sufficient to establish guilt beyond reasonable doubt, even if the accused later repudiate them at trial. Oral testimony regarding admissions made during preliminary investigations is admissible when the statutory requirement for written statements is not in force or was not followed.