People v. Maternal
REITERATIONFacts
The Antecedents: On August 27, 1969, Juan Cabasal left his house to sleep in his banca at Panamonton Beach, Brooke's Point, Palawan, bringing his radio-phono, bolo, and flashlight. When he did not return the following morning, his sister and brother searched for him. A search party found Juan Cabasal dead in the sea, about twenty meters from his banca. An autopsy revealed eleven lacerated wounds, five of which were fatal, caused by sharp and blunt instruments. Procedural History: The information filed was for robbery in band with murder. However, the trial court found the established facts to be simple robbery with homicide, with no more than three armed men participating. Accused Carlos R. Maternal, an escape-convict, was arrested in possession of the deceased's radio-phono. He confessed to the crime in an extrajudicial statement (Exhibit "C"), which was reduced to writing and sworn before a Municipal Judge. The trial court imposed the death penalty on Maternal, considering quasi-recidivism, but recommended executive clemency. Accused Zosimo Igao and Emilio Amar Jr. were acquitted due to lack of evidence. The Petition: Accused-appellant Carlos R. Maternal sought reversal, arguing that the trial court erred in admitting his extrajudicial confession, in holding him guilty based solely on the confession, and in imposing the death penalty.
Issue(s)
Whether the extrajudicial confession of the accused-appellant is admissible in evidence. Whether the accused-appellant is guilty of robbery with homicide based on his extrajudicial confession. Whether the penalty imposed by the trial court is correct.
Ruling
The judgment of conviction is AFFIRMED, and appellant Carlos R. Maternal is hereby sentenced to reclusion perpetua and to indemnify the heirs of the deceased Juan Cabasal in the sum of P30,000.00. With costs.
Ratio Decidendi
On the admissibility of the extrajudicial confession: The Court held that the extrajudicial confession (Exhibit "C") was admissible. The allegation of coercion and maltreatment was not corroborated by any evidence, such as a medical certificate, and was belied by the testimony of the Municipal Judge who administered the oath and confirmed the voluntary signing of the statement after it was read to the appellant. Furthermore, the detailed disclosures in the confession, which the police investigators could not have known, indicated its authenticity. The Court also clarified that a confession obtained before the effectivity of the 1973 Constitution is admissible even if the accused was not informed of his right to counsel, citing Magtoto vs. Manguera. On the guilt of the accused-appellant: The Court found the accused-appellant guilty of robbery with homicide. The confession, being freely and voluntarily given, is considered evidence of a high order, supported by the presumption that no person of normal mind would confess to a crime unless prompted by truth. The appellant did not deny his presence during the killing, only attempting to exculpate himself by attributing the act to his companions. The acquittal of the co-accused due to lack of confessions further supported the voluntariness of Maternal's confession, as it indicated that the police did not coerce all suspects into confessing. On the penalty imposed: The trial court correctly found the accused-appellant guilty and imposed the maximum penalty due to quasi-recidivism under Article 160 of the Revised Penal Code, as the crime was committed while serving sentence for a previous offense. However, due to lack of necessary votes, the penalty was reduced to reclusion perpetua.
Main Doctrine
An extrajudicial confession, if freely and voluntarily given, is evidence of a high order and is presumed voluntary until the contrary is shown. The fact that the confession was obtained before the effectivity of the 1973 Constitution does not render it inadmissible, even if the accused was not informed of his right to counsel.