People v. Aro
REITERATIONFacts
1. The Antecedents: Frankisio Aro and Pedro Lasala, inmates at the National Penitentiary, were convicted of murder for the stabbing death of fellow inmate Jose Mesina. The incident occurred within the prison compound. The prosecution alleged that the appellants, along with others, sought vengeance for the deaths of fellow inmates and attacked Mesina inside the Iglesia ni Kristo Chapel. Mesina sustained seventeen stab wounds, and medical examination suggested the possibility of multiple assailants or weapons. 2. Procedural History: The case originated from Criminal Case No. CCC-VII-1187-Rizal before the Circuit Criminal Court of Rizal. This court found the accused Frankisio Aro, Pedro Lasala, and Rodolfo Avila guilty of murder and sentenced them to death. The case was automatically reviewed by the Supreme Court. The appeal of Rodolfo Avila was dismissed after his death in prison. The Supreme Court affirmed the conviction of Frankisio Aro and Pedro Lasala but modified the sentence to reclusion perpetua due to a lack of sufficient votes for the death penalty. 3. The Petition: This case reached the Supreme Court through an automatic review of the Circuit Criminal Court's decision. The defendants-appellants, Frankisio Aro and Pedro Lasala, appealed their conviction for murder. Their defense primarily consisted of denials and claims of coercion and fabrication of evidence, asserting that their extrajudicial confessions were involuntary. The Supreme Court considered the eyewitness testimony of Benjamin Gagui and the appellants' own sworn statements, ultimately affirming their conviction while modifying the sentence.
Issue(s)
Whether the extrajudicial confessions of the appellants are admissible in evidence. Whether the guilt of the appellants for the crime of Murder was proven beyond reasonable doubt. Whether the aggravating circumstance of quasi-recidivism was correctly appreciated. Whether the penalty imposed by the trial court should be modified.
Ruling
The appealed decision is affirmed, with the modification that the accused-appellants Frankisio Aro and Pedro Lasala are sentenced to suffer the penalty of reclusion perpetua; to jointly and severally indemnify the heirs of Jose Mesina in the amount of P30,000.00, to pay P5,000.00 as moral damages, and P5,000.00 as exemplary damages, with costs.
Ratio Decidendi
On the admissibility of extrajudicial confessions: The Court reiterated its consistent ruling that where several accused, without collusion, make extra-judicial confessions which are identical in essential details and corroborated by other evidence, each confession is admissible against the other. This principle was applied to the sworn statements of appellants Frankisio Aro (Exhibit "G") and Pedro Lasala (Exhibit "M"), which admitted their participation in the stabbing of Jose Mesina. The Court found these confessions to be corroborated by the eyewitness testimony of Benjamin Gagui and by each other, thus satisfying the requirement for admissibility. On the proof of guilt beyond reasonable doubt: The Court found that the guilt of the appellants was proven beyond reasonable doubt. The eyewitness testimony of Benjamin Gagui was found to be consistent, sincere, and courageous, despite the potential for reprisal. Gagui positively identified appellants Aro and Lasala as participants in the stabbing. This eyewitness account was further corroborated by the appellants' own sworn statements, which admitted their involvement and even detailed the motive for the killing, which was to avenge the death of their Visayan co-inmates. The defense of denial and alibi offered by the appellants was deemed weak and uncorroborated, especially considering they were inmates within the prison compound where the crime occurred. On the appreciation of quasi-recidivism: The Court found that the aggravating circumstance of quasi-recidivism was applicable. It was established that appellant Frankisio Aro was serving sentence for robbery with homicide, and appellant Pedro Lasala was serving sentence for robbery at the time of the commission of the murder. Article 160 of the Revised Penal Code mandates that when a person commits a felony after having been convicted by final judgment, he shall be punished by the maximum period of the penalty prescribed by law for the new felony. This circumstance could not be offset by any mitigating circumstance. On the modification of the penalty: While the trial court imposed the death penalty, the Supreme Court, for lack of the necessary votes, modified the sentence to reclusion perpetua. This modification was made in accordance with the constitutional provision that no death penalty shall be imposed unless for compelling reasons involving heinous crimes and then only by a vote of at least ten (10) members of the Court. In this case, the penalty for murder, with the aggravating circumstance of quasi-recidivism, would ordinarily be death, but the lack of the required votes led to the imposition of reclusion perpetua.
Main Doctrine
Extrajudicial confessions, if identical in essential details and corroborated by other evidence, are admissible against each other. The aggravating circumstance of quasi-recidivism, when applicable, mandates the imposition of the maximum penalty prescribed by law for the new felony.