People v. Madlangbayan
REITERATIONFacts
The Antecedents: On December 27, 1970, in Manila, Enrique Fallarme, a supervising engineer, was supervising road construction. In the afternoon, his son Elywelyn gave him P300.00 in cash and a Seiko wrist watch, which Enrique placed in his wallet. Between 7:00 and 7:30 PM, Enrique Fallarme was stabbed to death by unknown assailants at the corner of San Gregorio and Canonigo streets. The autopsy revealed five stab wounds, with death caused by shock and hemorrhage. Upon arriving at the scene, Elywelyn Fallarme discovered his father dead and his wallet containing P300.00 and his Seiko wrist watch missing. Procedural History: The accused, Antonio Madlangbayan y Bonet, was arrested and subsequently identified the deceased as the person he had stabbed. He confessed his participation in the robbery and stabbing with three other individuals. His extrajudicial confession, taken in Tagalog and sworn before Fiscal Mariano Chavez, detailed the commission of the crime, including the robbery of cash and a wallet, and the stabbing of the victim. The accused also participated in a re-enactment of the crime. The trial court found the accused guilty beyond reasonable doubt as principal of the crime of robbery with homicide, appreciating the aggravating circumstance of abuse of superior strength without any mitigating circumstance, and sentenced him to death. The Petition: The accused appealed his conviction, maintaining that his extrajudicial confession was coerced and that he was maltreated by the police. He also presented a defense that he was at his uncle's residence during the time of the crime.
Issue(s)
Whether the extrajudicial confession of the accused was voluntary and admissible in evidence. Whether the extrajudicial confession, corroborated by evidence of corpus delicti, is sufficient to sustain a conviction for robbery with homicide. Whether the aggravating circumstance of abuse of superior strength was correctly appreciated.
Ruling
The judgment of the trial court finding the accused guilty beyond reasonable doubt of the crime of robbery with homicide and sentencing him to death is affirmed in its entirety.
Ratio Decidendi
On the voluntariness and admissibility of the extrajudicial confession: The Court held that the extrajudicial confession was voluntary and admissible. The presumption of voluntariness was not overcome by the appellant's mere testimony repudiating the confession. Evidence showed the confession was replete with details only the accused could have known, the fiscal administered the oath and confirmed the voluntary nature of the statement without any complaint of maltreatment, and the accused participated in a re-enactment of the crime. Furthermore, the accused did not present any medical certificate to show injury from alleged maltreatment. The Court reiterated that a confession has high evidentiary value and is presumed voluntary until the contrary is shown. On the sufficiency of the extrajudicial confession corroborated by corpus delicti: The Court found the extrajudicial confession sufficient to sustain the conviction when corroborated by evidence of corpus delicti. The Rules of Court require corroboration by evidence of corpus delicti, meaning the fact that a crime has actually been committed. In this case, the corpus delicti was sufficiently established by the uncontradicted testimonies of Elywelyn Fallarme and police officers, as well as the testimony of the medical examiner and the necropsy report, which proved the death of Enrique Fallarme. These facts, independent of the confession, tended to show that the crime of robbery with homicide had been committed. On the appreciation of the aggravating circumstance of abuse of superior strength: The Court affirmed the trial court's appreciation of the aggravating circumstance of abuse of superior strength. The accused, together with his co-assailants, took advantage of their superior strength when the four of them, armed with bladed weapons, surrounded and stabbed the unarmed, helpless, and unsuspecting victim. This circumstance was correctly considered by the trial court in imposing the penalty.
Main Doctrine
An extrajudicial confession, if voluntary and corroborated by evidence of corpus delicti, is sufficient to sustain a conviction for robbery with homicide.