People v. Saligan
REITERATIONFacts
The Antecedents: On July 2, 1972, after attending a burial, the victim, Teofista Maloloy-on, agreed to go home with the accused-appellant, Gomez Saligan, meeting him at a hanging bridge. The next day, July 3, 1972, the victim's dead body was discovered near the bridge. An autopsy revealed multiple stab and incised wounds, with the cause of death being hemorrhage secondary to these injuries. The victim's panty was found near her ankle, and her body was in a position suggestive of sexual intercourse. Procedural History: The accused was initially found guilty of "rape with homicide" and sentenced to death by the Court of First Instance. This Court, in a prior review, set aside the judgment due to procedural haste and ordered a new arraignment. Upon re-arraignment, the accused pleaded not guilty. The trial court subsequently found the accused guilty of Attempted Rape with Homicide and again sentenced him to death. The case was automatically reviewed by the Supreme Court. The Petition: The accused-appellant admitted to killing the victim but disputed the rape aspect, claiming it was only attempted rape or no rape at all. The prosecution, through the Solicitor General, maintained that rape was consummated.
Issue(s)
Whether the extrajudicial confession of the accused is admissible in evidence. Whether the rape was attempted or consummated. Whether the accused is guilty of the complex crime of rape with homicide.
Ruling
The Supreme Court affirmed the conviction of the accused-appellant for the complex crime of rape with homicide. The Court ruled that the extrajudicial confession was admissible and given due weight, and that rape was consummated, not merely attempted. The death sentence imposed by the lower court was affirmed.
Ratio Decidendi
On the admissibility of the extrajudicial confession: The Court held that the accused-appellant's extrajudicial confession (Exhibit "A") was admissible and entitled to due weight, despite his repudiation of it during the trial. The Court found that the police investigator and the municipal judge testified that the confession, though in English, was translated word-for-word to the accused in the Visayan-Cebuano dialect, which he understood fluently. The accused himself admitted to understanding and speaking this dialect. Furthermore, the accused acknowledged his signature on the affidavit and did not allege force or intimidation. The Court emphasized that while confessions in a language not understood by the declarant are generally disfavored, an exception exists when there is sufficient proof of translation and understanding, as was demonstrated in this case. The presumption of law favors the spontaneity and voluntariness of extrajudicial confessions, and the accused failed to destroy this presumption. On whether the rape was attempted or consummated: The Court ruled that rape was consummated, disagreeing with the trial court's finding of attempted rape. The Court cited the accused's extrajudicial confession stating he "was able to abuse her two times" and his admission that he "took out my penis and inserted in her vagina." While the autopsy did not recover semen or show vaginal bleeding/laceration, the Court relied on the medical findings of the body being in a "coital position," the victim's panty being found at her ankle, and the vagina being gaping, which indicated sexual intercourse. The Court also considered the contusions on the victim's body as evidence of struggle, suggesting force was used to remove her underwear and subdue her, supporting the conclusion of consummated rape. On the guilt for the complex crime of rape with homicide: The Court found the accused-appellant's culpability for the complex crime of rape with homicide to be fully and conclusively established by the evidence. The accused admitted to killing the victim with his bolo, and the evidence, including his hat found near the body and the bolo itself, corroborated this. The Court found the rape to be consummated, occurring before or during the infliction of some fatal wounds, and the homicide to be committed on the occasion of the rape. The Court rejected the defense's argument that the rape occurred after death, finding the accused's testimony unreliable and inconsistent. The Court concluded that the multiple injuries inflicted were proof of the accused's rage when the victim resisted his lust, and that the homicide was committed to silence her. Therefore, the penalty of death was affirmed.
Main Doctrine
An extrajudicial confession, even if repudiated, is admissible and must be given due weight if there is sufficient proof that its contents were translated and explained to the declarant, he understood the same, and the confession bears the earmarks of voluntariness. The presumption of law favors the spontaneity and voluntariness of an extrajudicial confession, and the burden is upon the declarant to destroy this presumption.