People v. Sajorda
REITERATIONFacts
The Antecedents: Roger Pereto y Manlapas and Victorio Sajorda y Campus were charged with murder for allegedly conspiring, confederating, and mutually helping each other to kill Receval Langlañgan with treachery and evident premeditation using sharp-pointed instruments while serving sentences in the New Bilibid Prison. Roger Pereto pleaded guilty and was sentenced to death. Victorio Sajorda pleaded not guilty. Procedural History: The Court of First Instance of Rizal found Victorio Sajorda guilty of murder, qualified by treachery, with the aggravating circumstances of evident premeditation and quasi-recidivism, and sentenced him to death. The case was elevated to the Supreme Court on automatic review. The Petition: The appeal centers on the evaluation of Sajorda's extra-judicial confession and his repudiation of it during trial, questioning whether his bare denial should be given more weight than his confession.
Issue(s)
Whether the extra-judicial confession of the accused Victorio Sajorda is admissible and entitled to full faith and credit. Whether the bare denial of the accused can be given more weight than his confession. Whether the accused Victorio Sajorda is guilty of murder.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance of Rizal, finding Victorio Sajorda guilty of murder and sentencing him to death. The Court gave full faith and credit to Sajorda's extra-judicial confession, finding it to be voluntarily and spontaneously given, and rejected his subsequent repudiation of the confession.
Ratio Decidendi
On the admissibility and weight of the extra-judicial confession: The Court held that Sajorda's extra-judicial confession (Exhibit B) could not be disregarded. Ample evidence showed it was made voluntarily and spontaneously. Inspector Gaudencio Jimenez testified that the answers were given by Sajorda in the presence of witnesses, that the statement was read to Sajorda, who then affixed his thumbmark and signature, and swore to its truth before the Acting Assistant Director of Prisons. The Court found no evidence to support Sajorda's claim that the statement was involuntary, other than his own self-serving repudiation during trial. The Court noted that Sajorda did not denounce the alleged falsity of the confession to the proper authorities before trial, which weakened his claim. The presumption of regularity in the performance of official duty by the investigating officers was upheld. On the weight of the accused's denial versus his confession: The Court emphasized that a bare denial by the accused cannot outweigh a confession, especially when the confession is corroborated by other evidence. Sajorda's claim that his confession was prepared by Inspector Jimenez without his intervention and that he could not read it due to his limited education was found unconvincing and uncorroborated. The Court reiterated that the repudiation of a confession for the first time during trial is often an afterthought to escape criminal responsibility. The trial court, having observed the demeanor of the witnesses, was in a better position to assess credibility, and its finding that the confession was voluntary was given great weight. On the guilt of the accused for murder: The Court found Sajorda's guilt established beyond reasonable doubt. The confession, corroborated by the autopsy findings of 43 wounds (38 stab wounds) on the victim, and the confiscation of the weapons used, did not align with Sajorda's claim that Roger Pereto acted alone. The confession also revealed specific details about the conspiracy and motives (grudge over sweepstakes tickets for Pereto, and a previous assault by the victim on Sajorda) that authorities could not have concocted. The aggravating circumstances of evident premeditation and quasi-recidivism were duly established by the evidence, leading to the affirmation of the murder conviction and the death penalty.
Main Doctrine
An extra-judicial confession, if voluntarily and spontaneously given, is entitled to full faith and credit and cannot be disregarded based solely on the accused's subsequent repudiation and self-serving insistence that it was prepared by authorities, especially when corroborated by other evidence and the accused fails to present evidence to overcome the presumption of voluntariness.