People v. Pizarro
REITERATIONFacts
The Antecedents: In the evening of June 6, 1971, spouses Teodoro Taban and Maria Pescador were killed inside their home, sustaining gunshot and stab wounds. The post-mortem examination revealed the cause of death to be shock secondary to hemorrhage from these wounds. Procedural History: The accused-appellant, Narciso Pizarro, son-in-law of the victims, was charged with double murder. The Court of First Instance of Cagayan convicted him and sentenced him to double death, with civil indemnities. The case was elevated for automatic review. The Petition: The accused-appellant appealed his conviction, primarily relying on the defense of alibi and alleging that his confessions were obtained under duress and maltreatment.
Issue(s)
Whether the defense of alibi can prevail over the positive identification of the accused-appellant by eyewitnesses. Whether the extrajudicial confessions of the accused-appellant are admissible in evidence, despite allegations of maltreatment and lack of counsel. Whether the accused-appellant is guilty beyond reasonable doubt of the crime of double murder.
Ruling
The appealed decision is AFFIRMED. However, for lack of the necessary votes, the penalty is reduced to double reclusion perpetua, and the indemnification to the heirs is increased to P30,000.00 for each victim.
Ratio Decidendi
On the defense of alibi versus positive identification: The Court held that the defense of alibi cannot prevail over the positive identification of the appellant by eyewitnesses. The Court reiterated the settled rule that alibi is the weakest of all defenses and should be rejected when the identity of the accused has been sufficiently and positively established. For alibi to prosper, it must be shown that it was physically impossible for the accused to have been at the scene of the crime at the time it was committed. In this case, the testimonies of Filomeno de los Santos and Felipe Jose provided positive identification of the appellant proceeding towards the victims' house and subsequently leaving the scene after gunshots were heard. On the admissibility of extrajudicial confessions: The Court found the extrajudicial confessions (Exhibits "C", "C-1", "C-2", "E", and "E-1") to be admissible. The statements were made voluntarily and reduced to writing after being read and understood by the appellant, who then signed them in the presence of a Municipal Judge. Furthermore, the confessions contained information not known to the police, such as the location where the murder weapon was buried, which was subsequently recovered. This corroboration strengthened the voluntariness and truthfulness of the confessions. The Court also noted that these confessions were obtained before the effectivity of the 1973 Constitution, and therefore, the lack of counsel at the time of their execution did not render them inadmissible, citing Magtoto vs. Manguera and People vs. Juliano. On the guilt of the accused-appellant: Based on the positive identification by eyewitnesses and the admissible extrajudicial confessions corroborated by the recovery of the murder weapon, the Court found the accused-appellant guilty beyond reasonable doubt of double murder. The appellant's claim of maltreatment was not substantiated and was contradicted by the detailed and corroborated nature of his confessions. The motive for the killing, as stated in the confession, was related to a property dispute and the victims' alleged disregard for the will of their daughter (the appellant's wife).
Main Doctrine
The defense of alibi cannot prevail over positive identification by eyewitnesses. Extrajudicial confessions, if voluntarily given and confirmed by subsequent discoveries, are evidence of a high order. Confessions obtained before the effectivity of the 1973 Constitution, even without the assistance of counsel, are admissible.