People v. De los Santos
REITERATIONFacts
The Antecedents: On November 29, 1971, Gregorio Dotado was found dead. An investigation revealed that the victim had a rival, Leonardo de los Santos (appellant), in courting Herminia Garcia. On December 6, 1971, appellant was picked up for questioning and the following day, voluntarily executed an affidavit confessing to the killing of Gregorio Dotado with Alfredo Lacastesantos, detailing the motive (misunderstanding at work and rivalry over Herminia Garcia) and the manner of the killing using a bolo and a knife, respectively. The post-mortem examination confirmed the wounds inflicted were consistent with the confession. Procedural History: Appellant Leonardo de los Santos and Alfredo Lacastesantos were charged with Murder. Appellant pleaded not guilty and was convicted by the former Court of First Instance of Basilan City, sentenced to reclusion perpetua, and ordered to indemnify the heirs. The case against Lacastesantos was dismissed due to insufficient evidence, as his implication stemmed solely from appellant's extrajudicial confession. Appellant appealed his conviction. The Petition: Appellant sought reversal of the conviction, arguing that his extrajudicial confession (Exhibit "D") was inadmissible because it was obtained through violence, threat, and intimidation, and its contents were belied by the prosecution's evidence.
Issue(s)
Whether the extrajudicial confession of the appellant was admissible in evidence. Whether the appellant was guilty of Murder.
Ruling
The judgment of the trial court convicting Leonardo de los Santos of Murder is affirmed, with the modification that the indemnity to the heirs of Gregorio Dotado is increased to P30,000.00.
Ratio Decidendi
On the admissibility of the extrajudicial confession: The Court held that the extrajudicial confession (Exhibit "D") was admissible. The appellant's claim of maltreatment on December 6, 1971, was deemed unbelievable as the confession was executed the following day, December 7, 1971, and the appellant himself testified that Patrolman Conrado Francisco did not maltreat or intimidate him during the investigation. Furthermore, the Clerk of Court, Ruben Ramos, testified that he asked the appellant if he was willing to sign the statement and if he was coerced or intimidated, to which the appellant responded negatively, stating he gave the statement voluntarily. The confession was replete with details only the confessant could have known, such as the victim drinking tuba at Manuel Martinez's house with specific companions and the exact locations of the wounds inflicted, which were corroborated by the post-mortem examination. The Court reiterated that a confession is deemed voluntary if the accused does not complain to proper authorities despite the opportunity, and that no sane person would confess to a crime without truth and conscience prompting them. The Court also noted that the confession was obtained before the 1973 Constitution took effect, thus the requisites regarding the right to remain silent and to counsel under that Constitution were not applicable retrospectively. The confession was corroborated by the evidence on the corpus delicti, specifically the post-mortem examination, which is sufficient for conviction. On the guilt of the appellant for Murder: Given the admissibility and voluntariness of the extrajudicial confession, which detailed the commission of the crime with treachery and evident premeditation as alleged in the Information, and its corroboration by the physical evidence (post-mortem examination), the Court found no reason to doubt the appellant's guilt. The confession established that the appellant and Alfredo Lacastesantos conspired to kill Gregorio Dotado due to a prior misunderstanding and rivalry over a woman. The appellant admitted to hacking the victim with a bolo, and Lacastesantos with a knife, resulting in the victim's death. The details provided in the confession, including the motive and the manner of inflicting the wounds, were consistent with the findings of the post-mortem examination, thereby establishing the corpus delicti and the appellant's participation in the crime of Murder.
Main Doctrine
An extrajudicial confession, if found to be voluntary and corroborated by evidence of the corpus delicti, is admissible and sufficient for conviction, even if the accused later attempts to repudiate it.