People v. Arcenal
REITERATIONFacts
The Antecedents: Shortly before midnight of September 5, 1972, Edgardo Funa was killed on the roadside in Panabo, Davao del Norte, sustaining seventeen stab and lacerated wounds. A few hours later, five security guards, including Benjamin L. Arcenal, Navy M. Padilla, and Ernesto V. Castro, were arrested. They had been playing billiards earlier, and Funa had watched the game. Subsequently, Arcenal, Padilla, and Castro signed affidavits about the killing before the municipal judge. Procedural History: A complaint for homicide was filed against Castro, Arcenal, and Padilla. After waiving the second stage of the preliminary investigation, an amended information for murder was filed against them. The lower court convicted Arcenal, Padilla, and Castro of murder, sentencing each to reclusion perpetua and ordering them to pay solidary indemnity to the heirs of Funa. The Petition: Only Arcenal appealed the decision, contending he was not a co-conspirator, did not assault Funa, and that the evidence against him was insufficient, asserting that only Padilla and Castro assaulted Funa. The conviction of Arcenal was based on Padilla's confession, which imputed that Arcenal also stabbed Funa with a pocket knife. Arcenal's own affidavit did not admit participation in the assault. Padilla later executed an affidavit retracting his confession, stating Arcenal did not participate in the killing.
Issue(s)
Whether the confession of Navy M. Padilla, implicating Benjamin L. Arcenal in the killing of Edgardo Funa, is sufficient to establish Arcenal's guilt beyond reasonable doubt. Whether the circumstantial evidence, coupled with Padilla's retracted confession, sufficiently proves Arcenal's participation in the murder of Edgardo Funa.
Ruling
The Court reversed and set aside the trial court's judgment convicting Arcenal of murder. Arcenal was acquitted on the ground of insufficiency of evidence and ordered to be released immediately unless detained for a lawful cause.
Ratio Decidendi
On the admissibility and sufficiency of Padilla's confession: The Court held that Padilla's confession, which implicated Arcenal, was admissible only against Padilla and not as conclusive proof of Arcenal's guilt. The prosecution conceded that the only evidence against Arcenal was the imputation in Padilla's confession and that there was no eyewitness testimony linking Arcenal to the killing. The Court reiterated the principle that a confession is evidence only against the person confessing. The Solicitor General's argument that Padilla's confession implicating Arcenal served as corroborative evidence was found unconvincing in the absence of independent evidence. The Court noted that Padilla, who finished second year high school, did not confirm in his testimony that Arcenal stabbed Funa, and even testified that he signed his confession without reading its contents. Furthermore, Padilla later executed an affidavit of retraction stating that Arcenal did not take part in the killing, which, although filed late, further weakened the prosecution's case against Arcenal. On the sufficiency of circumstantial evidence: The Court found that while Arcenal was with Padilla and Castro when Funa was killed, this fact alone, without more, did not establish his participation in the commission of the crime beyond reasonable doubt. Arcenal testified that he was not acquainted with Funa and implied no motive for him to participate in the killing. He positively stated that Padilla stabbed Funa, based on Padilla's admission to him. The Court concluded that the prosecution failed to present sufficient evidence to overcome the presumption of innocence in favor of Arcenal. The evidence presented did not meet the quantum of proof required for a conviction in a criminal case.
Main Doctrine
A confession implicating a co-accused is admissible only against the confessor and is not conclusive proof of the guilt of the co-accused, especially when the confessor later retracts the confession and the prosecution fails to present independent evidence establishing the co-accused's participation in the crime.