People v. Cañete
REITERATIONFacts
The Antecedents: Adriano Cañete and Jose Bilog were charged and convicted of murder for the killing of Douglas Bilog, Jose's brother. The prosecution presented evidence that Jose harbored resentment towards Douglas due to inheritance disputes and had previously attempted to hire someone to kill him. On the day of the incident, Douglas and Jose were seen drinking together. Two other individuals arrived, followed by appellant Adriano Cañete. Jose Bilog then drew a bladed instrument and stabbed Douglas. Cañete then took the knife and also stabbed Douglas. Douglas fought back, but with the help of others, he was subdued and killed, his body dumped in a canal. Cañete was later seen with bloodied clothes and exchanged them for another's. Cañete initially gave an extra-judicial confession admitting to the killing with others, but later retracted it, claiming it was concocted and that he was offered P1,000.00 to admit guilt. He also claimed the P1,000.00 was for executing the killing. Douglas Bilog sustained 26 injuries, including stab wounds to the heart and abdomen, leading to death by severe hemorrhage. Procedural History: The Court of First Instance of Palawan convicted both Adriano Cañete and Jose Bilog of murder, sentencing them to death and ordering them to pay jointly and severally P12,000.00 to the heirs of the deceased. The Petition: Both appellants appealed the decision. Adriano Cañete assailed his conviction, arguing his extra-judicial confession was inadmissible and that there were conflicting versions of the crime, raising reasonable doubt. He also argued against the presence of conspiracy, evident premeditation, and treachery, suggesting he should only be guilty of physical injuries or homicide. Jose Bilog challenged the credibility of prosecution witness Antonio Cabig and argued for his defense of alibi.
Issue(s)
Whether the extra-judicial confession of appellant Adriano Cañete was admissible and credible. Whether the defense of alibi of appellant Jose Bilog should be given credence. Whether the crime committed was murder, with the attendance of conspiracy, evident premeditation, treachery, and price. Whether the penalty and civil indemnity imposed by the trial court were proper.
Ruling
The Supreme Court affirmed the judgment of the trial court but modified the sentence. Both appellants were sentenced to suffer the penalty of reclusion perpetua and to indemnify, jointly and severally, the heirs of Douglas Bilog in the sum of P30,000.00.
Ratio Decidendi
On the admissibility and credibility of the extra-judicial confession: The Court held that appellant Cañete's extra-judicial confession (Exhibit "C"), given in April 1972, was freely and voluntarily given. There was no evidence presented to show it was obtained through violence, torture, intimidation, or promise of reward or leniency. The Court found Cañete's retraction to be a last-minute effort at exculpation. Even without the confession, the testimony of Antonio Cabig, who witnessed the incident, was sufficient to establish Cañete's participation in the killing. Cabig positively identified Jose Bilog stabbing Douglas and then Cañete stabbing Douglas with the same knife. On the defense of alibi: The Court found Jose Bilog's alibi to be without merit. His house was only three kilometers away from the scene of the incident, a distance that could be traversed. Furthermore, he was seen leaving his house on a bicycle before the incident and was met by another witness riding his bicycle around the time of the crime. The Court reiterated that alibi cannot prevail over positive identification by a credible witness, especially when the distance between the claimed location and the crime scene is not insurmountable. Courts are cautioned to exercise great care in accepting alibi as it is easily concocted. On the crime committed and attendant circumstances: The Court found that the killing of Douglas Bilog was qualified by treachery because the attack was unexpected and sudden, affording the victim no chance to defend himself. The aggravating circumstance of price was also present, as Jose Bilog had previously offered P300.00 to Nicasio Dayao to kill Douglas, indicating that the killing was committed for a consideration. This circumstance affects both the person who gave the price and the person who received it. The Court found sufficient evidence, including eyewitness testimony and the extra-judicial confession (though later retracted), to establish the conspiracy between Jose Bilog and Adriano Cañete in committing the murder. On the penalty and civil indemnity: The Court affirmed the conviction for murder. However, for lack of necessary votes to impose the death penalty, the sentence was modified to reclusion perpetua for both appellants. The civil indemnity awarded to the heirs of Douglas Bilog was increased from P12,000.00 to P30,000.00, consistent with prevailing jurisprudence at the time.
Main Doctrine
The Court affirmed the conviction for murder, modifying the sentence to reclusion perpetua and increasing the indemnity. It held that an extra-judicial confession, if voluntarily given and not obtained through violence or intimidation, is admissible and credible, even if later retracted. The Court also reiterated that alibi cannot prevail over positive identification by a credible witness, especially when the distance is not insurmountable. The presence of treachery and price were confirmed as qualifying and aggravating circumstances, respectively.