People v. Mariño
REITERATIONFacts
The Antecedents: The deceased, Enrique Fallarme, a civil engineer, and his son, Llywelyn Fallarme, left their residence for their store. After collecting sales, they proceeded to Paco, Manila, to inspect a road project where Enrique Fallarme was the Supervising Engineer. Llywelyn and his sister left their father at the project site to attend a piano recital. Later, Llywelyn was informed that his father had an accident and found him lifeless on the street with stab wounds. The victim's watch and wallet were missing. The medical report indicated death due to shock and hemorrhage from multiple stab wounds. Procedural History: Antonio Madlangbayan was arrested and, in a written statement, admitted to stabbing and robbing the deceased along with companions identified as Boy Mariño, Imping, and Rody, all members of the "Bahala Na Gang." Based on Madlangbayan's statement, the appellant, Edgardo Mariño, was arrested. Madlangbayan identified Edgardo Mariño as "Boy Mariño" in a police line-up. Edgardo Mariño gave a written statement to Patrolman Carag and later confirmed its truthfulness and voluntary execution before Fiscal Ramon Mabutas, also signing a sketch of a knife. The appellant denied the voluntary execution of his statement, claiming maltreatment. The trial court found the appellant guilty beyond reasonable doubt of robbery with homicide, with aggravating circumstances of abuse of superior strength and recidivism, and sentenced him to death. The Petition: The accused-appellant appealed the judgment, arguing that the trial court erred in admitting Antonio Madlangbayan's extra-judicial confession against him and in admitting his own extra-judicial confession and finding him guilty based on it.
Issue(s)
Whether Antonio Madlangbayan's extra-judicial confession is admissible against the herein appellant. Whether the appellant's extra-judicial confession is sufficient to sustain his conviction. Whether the appellant's extra-judicial confession was voluntarily given. Whether the aggravating circumstance of abuse of superior strength was correctly appreciated.
Ruling
The appealed judgment is affirmed, with the modification that the appellant is sentenced to reclusion perpetua, and the indemnity is increased to P30,000.00.
Ratio Decidendi
On the admissibility of Antonio Madlangbayan's extra-judicial confession: The Court held that while an extra-judicial confession of an accused is generally not admissible against a co-accused, it can serve as a strong indication of the appellant's participation when its contents interlock with the appellant's own statement. In this case, the interlocking nature of Madlangbayan's confession (Exhibit "E") and Mariño's statement (Exhibit "G"), with no proof of collusion and identical essential details, corroborated by medical findings, was admissible to prove conspiracy. Furthermore, the appellant's failure to object to the admission of Madlangbayan's confession during trial constituted a waiver of his right to question its admissibility on appeal. On the sufficiency of the appellant's extra-judicial confession for conviction: The Court reiterated the rule that an extra-judicial confession is not sufficient ground for conviction unless corroborated by evidence of the corpus delicti. In this case, the corpus delicti was sufficiently proven by the testimonies of Llywelyn Fallarme and the police officer, as well as the Medical Examiner's testimony and the necropsy report, which established the death of Enrique Fallarme and the cause thereof. The appellant's confession, detailing his participation in the robbery and homicide, was corroborated by these pieces of evidence. On the voluntariness of the appellant's extra-judicial confession: The Court found the claim of maltreatment to be belied by the evidence. The confession was replete with details only the accused could have known, including his movements prior to the crime. Moreover, Fiscal Ramon Mabutas, who administered the oath, confirmed that the appellant admitted the contents and voluntarily signed the statement and the sketch of the knife. The confession was made before the effectivity of the New Constitution, and thus, its provisions regarding the right against self-incrimination were not retroactively applied. On the aggravating circumstance of abuse of superior strength: The Court found that the aggravating circumstance of abuse of superior strength was correctly appreciated by the trial court. The evidence showed that the appellant, along with his co-accused, took advantage of their superior strength when the four of them, two armed with deadly weapons, surrounded and stabbed the unarmed, helpless, and unsuspecting victim. However, due to the lack of necessary votes, the Court imposed the next lower penalty, reclusion perpetua, instead of death.
Main Doctrine
An extra-judicial confession, to be sufficient for conviction, must be corroborated by evidence of the corpus delicti. The corpus delicti of robbery with homicide is proven by evidence of the death of the victim and the fact that the death was caused by a criminal act, and that the accused committed the act.