People v. Guillermo
REITERATIONFacts
The Antecedents: On May 10, 1972, at about 5:30 A.M., in Barrio Lamonan, Passi, Iloilo, Billardo Gardoce was shot and killed during a robbery. The perpetrators, identified as Ariston Guillermo, Carlito Aborde, Ronito Cullo, and Jesus Cullo, also took P500 cash, a .22 caliber paltik revolver, and a 12-gauge homemade shotgun from Vicente Gardoce. The prosecution's version, testified to by Vicente and Benedicto Gardoce, stated that the accused entered the Gardoce residence, subdued Benedicto and Godofredo, tied their hands, and then Ariston Guillermo shot Billardo Gardoce with a homemade shotgun when Billardo inquired about the commotion. Vicente Gardoce was compelled to surrender money and his shotgun under threat of death to his sons. The accused threatened the Gardoces with death if they reported the incident to the police. Procedural History: The Court of First Instance of Iloilo, Branch IV, convicted Ariston Guillermo, Carlito Aborde, Ronito Cullo, and Jesus Cullo of robbery in band with homicide and sentenced each to suffer reclusion perpetua, with joint and several indemnification for damages. The accused appealed. The Petition: The accused-appellants raised issues concerning the admissibility of the extrajudicial confessions of Ariston Guillermo and Carlito Aborde, the alleged inconsistencies and improbabilities in the prosecution's evidence, the trial court's disregard of their evidence, and the sufficiency of identification, with Guillermo and Aborde alleging they were victims of a frame-up.
Issue(s)
Whether the extrajudicial confessions of Ariston Guillermo and Carlito Aborde (Exhibits "A" and "B") are admissible in evidence. Whether the guilt of accused-appellants Ronito Cullo and Jesus Cullo was established beyond reasonable doubt. Whether the guilt of accused-appellants Ariston Guillermo and Carlito Aborde was established beyond reasonable doubt even without the extrajudicial confessions.
Ruling
The Court affirmed the conviction of Ariston Guillermo and Carlito Aborde but acquitted Ronito Cullo and Jesus Cullo on the ground of reasonable doubt. The Court ordered an investigation into the manner in which the extrajudicial confessions were obtained and prosecution of the police officers involved if warranted.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the extrajudicial confessions (Exhibits "A" and "B") of Ariston Guillermo and Carlito Aborde were inadmissible in evidence. The trial court's reliance on People vs. de los Santos (G.R. No. L-4880, May 18, 1953), which held that the admissibility of evidence is not affected by the illegality of the means, was explicitly abandoned, as the prevailing rule, reiterated in Stonehill vs. Diokno (G.R. No. L-19550, June 19, 1967), and enshrined in Section 20, Article IV of the 1973 Constitution, dictates that illegally obtained evidence, especially coerced confessions, is inadmissible. Evidence showed that the confessions, written in English, were prepared by the Chief of Police while the affiants did not understand English, were initially refused to be signed, and were obtained under threats of further maltreatment. The physical examination conducted more than two months after the alleged maltreatment was deemed inconclusive. The Court found lingering doubts about the voluntariness of these confessions, which must be resolved in favor of the accused. On Issue 2: The Supreme Court acquitted Ronito Cullo and Jesus Cullo due to reasonable doubt. Even assuming the extrajudicial confessions of Guillermo and Aborde were admissible, they could not be used against the Cullo brothers due to the res inter alios acta rule (Section 25, Rule 130 of the Rules of Court). This rule requires independent evidence of conspiracy before a conspirator's declaration can be used against co-conspirators. While the prosecution presented direct testimonies of Vicente and Benedicto Gardoce, their initial affidavits, signed shortly after the incident, stated that Guillermo and Aborde's companions were unknown or unidentified, and the initial complaint named different individuals (Estorque) before being amended to include the Cullos. These inconsistencies created serious doubt regarding the Cullo brothers' participation, which, combined with the strengthening of their alibi, necessitated their acquittal. On Issue 3: The Supreme Court affirmed the conviction of Ariston Guillermo and Carlito Aborde, finding their guilt established beyond reasonable doubt even without their extrajudicial confessions. The direct testimonies of Vicente and Benedicto Gardoce, despite their flaws concerning the identification of the Cullo brothers, consistently and unerringly pointed to Guillermo and Aborde as active participants in the crime. Specifically, Guillermo was identified as the one who shot Billardo Gardoce and received the stolen money and firearms, while Aborde allegedly fired a shot in the air. The Court found no sufficient indications that the Gardoces falsely testified against Guillermo and Aborde, nor any shown motive for them to do so. Their straightforward narration of the events and the participation of these two accused constituted ample evidence to sustain their conviction.
Main Doctrine
Extrajudicial confessions obtained through force, violence, threat, or intimidation are inadmissible in evidence, and the illegality of the means by which evidence is secured does not affect its admissibility under prevailing jurisprudence and constitutional provisions. Furthermore, confessions of co-conspirators are inadmissible against other co-conspirators under the res inter alios acta rule absent independent evidence of conspiracy.