People v. Beralde
REITERATIONFacts
The Antecedents: On the night of July 31, 1968, Constantino Bose and Consolacion Bandayrel Bose were found dead in Bangued, Abra. The investigation led to the arrest of Luis Beralde. Beralde, in an extrajudicial confession, admitted to killing the couple, claiming the motive was that Consolacion Bose was a witch who had caused his wife's illness. He described the manner of killing and the weapon used, which was later recovered. Procedural History: The accused, Luis Beralde, was charged with double murder. The trial court convicted him, sentencing him to two sentences of reclusion perpetua and ordering him to indemnify the heirs of the victims. The defense presented alibi, which the trial court did not give credence to. The Petition: The appellant, Luis Beralde, appealed the decision, arguing that his extrajudicial confession was inadmissible, involuntary, and uncorroborated. He also contended that his defense of alibi should have been given weight and that he should have been acquitted due to reasonable doubt.
Issue(s)
Whether the extrajudicial confession of the appellant is admissible and voluntary. Whether the defense of alibi should be given credence. Whether the appellant is guilty of double murder.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the appellant guilty of two separate crimes of murder. The Court sentenced him to suffer two reclusion perpetuas and to indemnify the heirs of each victim in the sum of P12,000.00. The Court also ordered that the forty-year limit in Article 70 of the Revised Penal Code be observed in the service of the sentences.
Ratio Decidendi
On Whether the extrajudicial confession of the appellant is admissible and voluntary: The Supreme Court held that the extrajudicial confession of Luis Beralde was admissible and voluntary. The Court found that the appellant's claims of maltreatment were self-serving and unsubstantiated, contradicted by the testimonies of the Chief of Police and the Municipal Judge, who were presumed to have performed their duties regularly. The confession was detailed, containing information only the perpetrator could know, such as the motive, the place and time of the killing, the encounter with Police Eduardo Bringas, and the location of the hidden weapon, which was later recovered. The Court also noted that the right to counsel during custodial investigation was not yet applicable at the time of the confession in 1968, as the relevant constitutional provision was enacted later. The alleged discrepancies in age and time of death were deemed minor and sufficiently explained or intended to mislead. The Court emphasized that motive is not a necessary element of a crime, and the alleged motive was provided by the appellant himself. On Whether the defense of alibi should be given credence: The Supreme Court ruled that the defense of alibi presented by the appellant was not credible. The Court found that the proximity of the appellant's residence to the scene of the crime did not preclude his presence there. Furthermore, the appellant admitted to being at the scene of the crime around 8:00 p.m. on the night of the incident, which was corroborated by Police Eduardo Bringas. The Court reiterated that for alibi to prosper, it must not only show the defendant was elsewhere but also that it was physically impossible for him to have been at the scene of the crime. Given the appellant's admission and the short distance, his alibi was deemed insufficient to overcome the evidence against him. On Whether the appellant is guilty of double murder: The Supreme Court affirmed the conviction for double murder, but clarified that the appellant was guilty of two separate crimes of murder, not a complex crime of double murder. The Court found that the killing of Consolacion Bose was qualified by treachery, as she was attacked from behind, preventing any defense. Regarding Constantino Bose, the Court rejected the appellant's claim that Constantino attacked him first. The Court relied on the testimonies of Dr. Luis Bringas and Chief of Police Narciso Laureta, who observed that Constantino's bolo was still in its scabbard underneath his body, and he was found holding the rope of his cow with the yoke of his plow still on his shoulder, indicating he was returning from the fields and not engaged in a fight. This established that Constantino was also attacked treacherously, without opportunity to defend himself. The Court also found that evident premeditation was not sufficiently proven, as there was no clear evidence of the time Beralde determined to commit the crime, acts indicating his determination, or a sufficient lapse of time for reflection. However, the qualifying circumstance of treachery was present in both killings.
Main Doctrine
An extrajudicial confession, even if repudiated, is admissible and can be the basis for conviction if it is corroborated by proof of corpus delicti and found to be voluntary and credible, especially when the defense of alibi is weak and unsubstantiated. The absence of eyewitnesses does not preclude conviction if the confession is sufficiently corroborated.