People v. De la Cruz
REITERATIONFacts
The Antecedents: Cesar de la Cruz alias Oscar, along with others, was accused of robbery in band with rape. The amended information alleged that on May 12, 1963, the accused, armed and in conspiracy, by means of force and intimidation, robbed Fernando Salazar of cash and valuables. On the same occasion, they allegedly took Carmelita Salazar from her house, dragged her under the house of her uncle, and there, by means of force and grave abuse of superior strength, committed rape against her will. Procedural History: The Court of First Instance of Tarlac found Cesar de la Cruz alias Oscar and Leonardo Altura guilty beyond reasonable doubt of robbery with rape, attended by aggravating circumstances of being committed by a band and by night time purposely sought. They were sentenced to reclusion perpetua. Both appealed to the Court of Appeals. The case against Altura was dismissed upon his death. The Court of Appeals, upon realizing it lacked jurisdiction due to the penalty imposed, certified the case to the Supreme Court. The Petition: Cesar de la Cruz, the lone appellant, prayed for the reversal of his conviction, arguing that the trial court erred in finding him to have participated in the robbery and in admitting his extrajudicial confession. He claimed no witness testified to his presence at the scene of the crime, and his confession was obtained through force and intimidation.
Issue(s)
Whether the trial court erred in finding the appellant participated in the robbery. Whether the appellant's extrajudicial confession was admissible in evidence.
Ruling
The Supreme Court affirmed the judgment of the Court of Appeals, upholding the conviction of Cesar de la Cruz alias Oscar for robbery with rape. The Court found the extrajudicial confession to be admissible and voluntary, and the evidence sufficient to establish his participation in the crime. The Court also recommended Cesar de la Cruz for executive clemency due to his long period of detention.
Ratio Decidendi
On the issue of participation in the robbery: The Court found that while no witness directly testified to seeing the appellant at the scene of the crime, the testimony of Calixto Gabuya, placing the appellant in the proximate vicinity of the crime scene on the night in question, supported his extrajudicial confession. The Court noted that Gabuya testified that a group of about ten men, including Cesar de la Cruz, ate at his house in barrio Balite before proceeding to barrio Linao. This proximity, coupled with the detailed confession, was deemed sufficient to support the finding of participation. On the admissibility of the extrajudicial confession: The Court rejected the appellant's claim that his confession was obtained through force and intimidation. The Court reiterated the rule that a confession is presumed voluntary until the contrary is proved, and the burden of proof lies with the confessor. The appellant failed to overcome this presumption. Firstly, he did not submit to a medical examination to support his claims of physical injuries. Secondly, he did not complain to the Municipal Judge at the time of signing. Judge Cabarios testified that he took precautions, excluded military personnel, translated the confession's contents, and observed no injuries, fatigue, or fear in the appellant and Leonardo Altura when they affirmed their willingness to sign. The Court also noted that the confession was replete with details only the appellant could have supplied, further indicating its voluntariness. The Court also addressed the appellant's claim of not being apprised of his constitutional rights, noting that while the specific rights were not detailed, the Miranda doctrine was not mandatory in 1964, and the 1973 Constitution's provision had no retroactive effect. The presence of the question regarding being apprised of constitutional rights in the confession itself, even if the specifics were not elaborated, lent credence to the process.
Main Doctrine
An extrajudicial confession is presumed to be voluntary until the contrary is proved, and the burden of proof rests upon the person who gave the confession. The presumption is not overcome by unsubstantiated claims of force or intimidation, especially when the confession is replete with details and the circumstances of its execution, including the affirmation before a judge and the lack of medical evidence of injury, belie the claim of involuntariness.