People v. Mateo
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the murder of Manuel Pascual, a 34-year-old tricycle driver, whose body was discovered on October 9, 1981, with thirteen incised and stab wounds. The victim was last seen the night before. His tricycle was found abandoned on the roadside, and a bolo, a potential weapon, was discovered nearby. 2. Procedural History: Approximately two weeks after the discovery of the body, five suspects—Fidel Mateo, Elmer Dajugar, Rene Ambrocio, Florante Martinez, and Edwin Aglugob—were arrested and provided extrajudicial confessions. The case proceeded to trial, during which three of the accused (Ambrocio, Aglugob, and Martinez) changed their pleas to guilty. Aglugob and Ambrocio were subsequently found guilty but had their sentences suspended and were committed to the custody of social services. Martinez withdrew his guilty plea and reverted to not guilty. The trial court, in a subsequent decision, found Mateo and Dajugar guilty of murder, sentencing them to reclusion perpetua, and ordered them to pay civil indemnity. Mateo did not appeal, and Martinez was also committed to social services. Only Dajugar appealed his conviction. 3. The Petition: Accused-appellant Elmer Dajugar contends that the trial court erred in admitting his confession, alleging he was maltreated and not properly informed of his right to counsel, particularly the right to have one appointed if indigent. He argues that without his confession, there is insufficient evidence of his complicity. The Solicitor General recommends acquittal on these grounds. Dajugar also argues that he is not guilty of murder, that the alleged aggravating circumstances were not proven, and that he is entitled to a one-degree reduction in penalty as he was under eighteen at the time of the offense.
Issue(s)
Whether the extrajudicial confession of the appellant was admissible in evidence. Whether the appellant is guilty of murder. Whether treachery, evident premeditation, abuse of superior strength, nighttime, and drunkenness were proven as aggravating circumstances. Whether the appellant is entitled to a one-degree reduction of his penalty for being a minor offender.
Ruling
The Court affirmed the conviction of appellant Dajugar for murder but modified the sentence. Dajugar was sentenced to four years, two months, and one day of prision correccional as minimum to ten years and one day of prision mayor as maximum. The lower court's judgment in other respects was affirmed.
Ratio Decidendi
On the admissibility of the extrajudicial confession: The Court held that while Dajugar's confession might be questionable due to the admonition only informing him of his right to remain silent and to hire a lawyer, not that a lawyer would be provided if indigent, the admissibility of his confession was not the sole basis for his conviction. The Court considered the five extrajudicial confessions of the co-accused, which were independently made, identical in essential details, and corroborated by other evidence, specifically the eyewitness testimony of Froilan Ramirez. These confessions, even if not directly admissible against Dajugar, served as circumstantial evidence to show the probability of his participation in the crime. The admissibility of the four confessions of Dajugar's co-accused was not in question in the appeal, and their recitals regarding Dajugar's involvement, partly corroborated by Ramirez's testimony, constituted evidence against him. On the guilt of the appellant for murder: The Court found sufficient evidence proving that appellant Dajugar was a co-principal in the killing of Manuel Pascual. The confessions of the co-accused, corroborated by the eyewitness testimony, established his participation. The killing was qualified by abuse of superior strength, as the five accused ganged up on the victim. The fiscal's characterization of this as a generic aggravating circumstance was deemed mistaken by the Court. On the aggravating circumstances: The Court found that the circumstances of treachery and evident premeditation, which were alleged in the information as qualifying circumstances, were not proven. Intoxication was considered mitigating as it was non-habitual and unintentional. Abuse of superior strength was considered as qualifying the crime, not merely an aggravating circumstance, due to the concerted action of the five accused against one victim. On the entitlement to a one-degree reduction of penalty: The Court ruled that Dajugar was entitled to a one-degree reduction of his penalty because he was below eighteen years of age at the time of the commission of the crime. He was exactly 17 years, 11 months, and 28 days old. Therefore, the maximum of his indeterminate sentence was taken from prision mayor maximum, and the minimum from prision correccional maximum, as provided by Article 68 of the Revised Penal Code.
Main Doctrine
Extrajudicial confessions, independently made without collusion, which are identical with each other in their essential details and are corroborated by other evidence on record, are admissible as circumstantial evidence against the person implicated to show the probability of the latter's actual participation in the commission of the crime. While confessions of a co-conspirator are not ordinarily admissible as evidence against another co-conspirator, the fact that they implicate the latter and were made soon after the commission of the crime, is circumstantial evidence to show the probability of their co-conspirator having actually participated therein.