People v. Peña
REITERATIONFacts
The Antecedents: On July 10, 1961, Roberto Monreal, a detained prisoner in Cell 2-A of the City Jail of Manila, was attacked and killed. The information alleged that the accused, Ramon Narciso, Elias Gloria, Francisco Celso, and Rufino Peña, all detained prisoners, willfully, unlawfully, and feloniously, with intent to kill, evident premeditation, treachery, and superior strength, attacked Monreal with pieces of wood, inflicting mortal injuries. Procedural History: All accused pleaded not guilty. The prosecution presented several witnesses and exhibits, including necropsy reports and extrajudicial statements of the accused. Accused Francisco Celso's case was dismissed for insufficiency of evidence. Accused Elias Gloria escaped and remained at large. Accused Ramon Narciso died during the pendency of the case. The trial proceeded against Rufino Peña, who was convicted of murder and sentenced to death. The Petition: This case is an automatic review of the conviction of Rufino Peña. The defense argued that Peña's extrajudicial confession was involuntary due to alleged maltreatment and that the eyewitness testimony did not sufficiently implicate Peña.
Issue(s)
Whether the extrajudicial confessions of the co-accused are admissible against Rufino Peña. Whether Peña's extrajudicial confession was voluntary and admissible despite his allegations of torture. Whether Peña can be convicted of consummated murder in the absence of an allegation of conspiracy in the Information.
Ruling
The Supreme Court modified the decision of the lower court. Rufino Peña was found guilty not of consummated murder, but of attempted murder. He was sentenced to two (2) years, four (4) months, and one (1) day of prision correccional to eight (8) years of prision mayor, and to pay the heirs of the offended party the sum of P500.00.
Ratio Decidendi
On Issue 1: The Supreme Court held that the extrajudicial statements of Elias Gloria and Francisco Celso are inadmissible as direct proof of specific facts against Rufino Peña under the rule of res inter alios acta. Since these statements were not repeated in open court, they constitute hearsay as against Peña, who was denied the opportunity for cross-examination. However, the Court qualified this by stating that when multiple confessions are identical in material respects and were made without collusion, they may be taken into consideration as a circumstance in judging the credibility of the accused's own testimony or confession. Therefore, while Exhibits J and M were not direct evidence of Peña's participation, the trial court did not err in noting their substantial alignment with Peña's own confession to assess his credibility. On Issue 2: The Court ruled that Peña's confession was voluntary. The Court dismissed the allegations of torture because Peña failed to present any medical evidence or the testimony of the doctor who allegedly examined his injuries, even after being prompted by the prosecution. The Court observed that the confession was 'replete with details' and 'reflects spontaneity and coherence,' with answers that were responsive and informative. Relying on the presumption of regularity in the performance of official duties by the police officers, the Court found no evidence of confabulation. The lack of suspicious circumstances on the face of the document further supported the finding that the confession was not coerced. On Issue 3: The Supreme Court modified the conviction from Murder to Attempted Murder. It emphasized that because the Information did not allege conspiracy, Peña could only be held responsible for his individual participation. The medical evidence identified two fatal lacerations at the back of the head and one non-fatal superficial wound near the eye. Based on the eyewitness testimony and the confessions, the Court deduced that Peña inflicted the first, non-fatal blow while the victim was lying on his back, whereas the fatal blows were delivered by Gloria after the victim had turned onto his belly. Since the wound attributed to Peña was not the cause of death and his liability could not be extended to the acts of others without a conspiracy charge, the stage of execution was merely attempted, despite the manifest intent to kill.
Main Doctrine
An extrajudicial confession, even if admissible, requires corroboration by evidence of corpus delicti for conviction. The testimony of an eyewitness, even if limited in scope, can corroborate a confession. The voluntariness of a confession is presumed unless overcome by clear and convincing evidence of maltreatment.