People v. Ribadajo
REITERATIONFacts
The Antecedents: On November 18, 1971, at approximately 7:56 PM, inmates from Brigade 3-C of the New Bilibid Prison, Muntinlupa, used a false key to open their dormitory door and attacked inmates from dormitory 3-A who were collecting food rations. The victim, Bernardo Cutamora, was among those getting rations and was simultaneously stabbed by the accused, sustaining multiple stab wounds that caused his death. The accused confessed that their motive was to avenge mockery by inmates of Brigade 3-A, who belonged to the OXO gang, including an incident where human waste was thrown on their brigade. They planned the killing in the afternoon of the same day, targeting inmates from Brigade 3-A during their food ration distribution. Procedural History: An investigation on November 20, 1971, led to the execution of statements by the accused admitting participation. An Information for Murder was filed on April 24, 1973. Upon arraignment on July 5, 1973, Tobias Ribadajo, Romeo Corpuz, Loreto Rivera, and Rodolfo Torres pleaded Guilty, while Federico Basas and Rosendo Anor pleaded Not Guilty. The Information was amended to correct Rosendo Anor's name. During the presentation of defense evidence, Ribadajo, Corpuz, and Torres withdrew their guilty pleas and denied participation, claiming duress. Basas and Torres admitted their confessions, and Anor changed his plea to Guilty for Homicide. The trial court found all accused guilty of Murder and sentenced them to death. The Petition: The accused appealed the trial court's decision, arguing that their extrajudicial confessions were inadmissible due to force and maltreatment, that the aggravating circumstances of treachery, evident premeditation, and recidivism were erroneously found, and that they should not have been convicted of murder and sentenced to death.
Issue(s)
Whether the trial court erred in admitting and giving weight to the extrajudicial confessions of the accused. Whether the trial court erred in finding the presence of the aggravating circumstances of treachery, evident premeditation, and recidivism. Whether the trial court erred in convicting the accused of murder and imposing the death penalty.
Ruling
The judgment of conviction is affirmed. However, for lack of the necessary votes, the penalty imposed on all the accused-appellants is reduced to reclusion perpetua. The indemnity to be paid to the heirs of the deceased is raised to P30,000.00. Proportionate costs are against the accused.
Ratio Decidendi
On the admissibility and weight of extrajudicial confessions: The Court found no sufficient basis to destroy the presumption of voluntariness of the appellants' confessions. The confessions were replete with details only the appellants could have supplied, such as nicknames of co-accused and the specific plan of attack, including the use of a false key and improvised weapons. The Court reiterated that mere repudiation of a confession by the accused at the trial is not sufficient to disregard it; concrete evidence of compulsion or duress must be presented. The appellants failed to present such evidence, and no report of maltreatment was made to prison authorities or the fiscal. Furthermore, the Court noted that the right to be informed of the right to silence and to counsel during custodial investigation, as guaranteed by the 1973 Constitution, does not have retroactive effect, and the confessions were obtained prior to its effectivity. On the presence of aggravating circumstances: The Court affirmed the trial court's finding of treachery, evident premeditation, and recidivism. Treachery was present because the attack was sudden, unexpected, and the victim was unarmed and deprived of any opportunity to defend himself or retreat. Evident premeditation was established by the plan to kill any prisoner from Brigade 3-A, hatched around 1:00 PM and consummated around 8:00 PM on the same day, indicating ample time for reflection and opportunity to desist. Recidivism was considered because all the accused were serving sentences for prior crimes embraced within the same title of the Revised Penal Code at the time of the commission of the offense. On the conviction for murder and imposition of the death penalty: The Court found no error in convicting the accused of murder. The penalty for murder is reclusion temporal in its maximum period to death. Considering the presence of recidivism, the appellants should be punished by the maximum period of the penalty prescribed by law for murder. The Court also clarified that the crime was not "Death Caused in a Tumultuous Affray" as there was no confusion, tumultuous quarrel, or reciprocal aggression; instead, there was a common purpose to attack the victim, indicating common responsibility. Although the trial court imposed the death penalty, the Supreme Court, for lack of necessary votes, reduced the penalty to reclusion perpetua.
Main Doctrine
Extrajudicial confessions, even if repudiated, are admissible and carry weight if replete with details only the appellants could have supplied. The presumption of voluntariness of confessions is strong, and mere repudiation without concrete evidence of compulsion is insufficient to disregard them. The 1973 Constitution's safeguards on custodial investigations do not have retroactive effect.