People v. Dorado
REITERATIONFacts
The Antecedents: On September 2, 1962, a five-door apartment and an adjacent residential house in Castillejos, Quiapo, Manila, were burned. The incident resulted in the death of 21 persons and injuries to 5 others. Procedural History: The appellant, Gavino Dorado y Arabaca, surrendered to the Mayor of Malabon, Rizal, and was turned over to the Manila Police Department. He executed a handwritten confession on September 4, 1962, followed by a more detailed statement to a police investigator. He also reenacted the crime on September 5, 1962. An information for arson with multiple homicide and multiple frustrated homicide was filed against him. The Court of First Instance of Manila found him guilty and sentenced him to reclusion perpetua. The Appeal: The defendant-appellant appealed the decision of the trial court, contending that the court erred in finding him guilty based on his extrajudicial confessions. He claimed that the confessions and the reenactment of the crime were obtained through force and violence applied by the police investigators. He asserted that he wrote his confession as dictated and that he affirmed its contents before the fiscal only because he was accompanied by a policeman, intending to expose the maltreatment in court.
Issue(s)
Whether the extrajudicial confessions of the appellant were admissible as evidence, given his claim of coercion and torture. Whether the trial court erred in finding the appellant guilty of arson with multiple homicide and multiple frustrated homicide based on his confessions.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the appellant guilty of arson with multiple homicide and multiple frustrated homicide. The Court held that the extrajudicial confessions were voluntary and admissible, and that the trial court did not err in relying on them to convict the appellant. The sentence of reclusion perpetua was upheld, with costs against the defendant-appellant. The offended parties reserved their right to institute separate civil actions for damages.
Ratio Decidendi
On Issue 1: The Supreme Court held that the extrajudicial confessions of the appellant were admissible as evidence. The Court found no reason to give credence to the appellant's claim of torture and intimidation, as it was not supported by any evidence other than his own testimony. The Court noted that the appellant wrote and signed his confession in the presence of newspaper reporters, and that his subsequent statement was subscribed and sworn to before an assistant city fiscal. The details mentioned in the confession, such as his educational attainment, personal grievances, and movements after the incident, were specific and could only have been known by the declarant, thus corroborating the voluntariness of the confession. The Court reiterated the rule that a confession is presumed to be voluntary until the contrary is shown, and that it would be an unsound practice to disregard a confession simply because the accused repudiates it during the trial without sufficient proof. On Issue 2: The Supreme Court ruled that the trial court did not err in finding the appellant guilty of arson with multiple homicide and multiple frustrated homicide. The Court found that the appellant's confessions were clear, detailed, and corroborated by the corpus delicti (the fact that the building was indeed burned, resulting in deaths and injuries). The Court emphasized that it is not necessary for an eyewitness to testify to the commission of the crime if the accused has confessed voluntarily and the confession is supported by the corpus delicti. The Court agreed with the trial court's observation that the appellant's grievance against the owner of the apartment likely motivated the crime, and that his subsequent confession was an act of remorse, later repudiated due to the grave implications.
Main Doctrine
Extrajudicial confessions are admissible as evidence if proven to be voluntary and corroborated by the corpus delicti. The presumption of voluntariness of a confession can only be overcome by clear and convincing evidence of duress or coercion. Appellate courts are bound by the trial court's findings of fact, including the credibility of witnesses and the voluntariness of confessions, unless there is a showing of grave abuse of discretion or overlooking of material facts.