People v. Pamon
REITERATIONFacts
The Antecedents: On July 26, 1985, Robert Te was shot and killed while maneuvering his truck, which had gotten stuck in the mud. Cesar Siga was also hit by a stray bullet. The truck was subsequently burned. Initial investigations pointed to the NPA, but later investigations identified Fortunato Pamon as the killer. Procedural History: Fortunato Pamon executed a confession admitting to the killing of Robert Te and implicating Gerson Dulang and others. An information for murder was filed against Pamon (principal by direct participation), Feras and Dulang (principals by induction), and John Doe (accomplice). Feras died during trial, and the information was amended to substitute Dulang for Feras as principal by induction. The trial court convicted Pamon and Dulang of murder. The Petition: Both Pamon and Dulang appealed the decision of the Regional Trial Court, raising issues regarding the admissibility of Pamon's confession, the validity of his arrest, and the sufficiency of evidence against Dulang.
Issue(s)
Whether Fortunato Pamon's extrajudicial confession is admissible in evidence. Whether Fortunato Pamon's arrest was valid. Whether Gerson Dulang's conviction is supported by sufficient evidence beyond reasonable doubt. Whether the trial court erred in admitting the amended information and trying Gerson Dulang under it.
Ruling
The Supreme Court affirmed the conviction of Fortunato Pamon for murder but reversed and set aside the conviction of Gerson Dulang due to reasonable doubt. The Court held that Pamon's extrajudicial confession was admissible and validly obtained, but it could not be used against Dulang.
Ratio Decidendi
On the admissibility of Fortunato Pamon's extrajudicial confession: The Court held that the confession was admissible. It found that Pamon failed to present sufficient proof of maltreatment, as he did not submit any medical certificate and did not file any complaint against his alleged tormentors despite opportunities. The Court noted that the prosecution's witness testified that the examining physician found no signs of physical maltreatment. Furthermore, Pamon had several chances to deny the confession's voluntariness but instead reaffirmed it during the preliminary investigation. The presence of counsel, Atty. Rubencio Ligorio, and the signatures of the counsel and the judge who administered the oath were considered earmarks of voluntariness. The Court also found that while Pamon claimed Atty. Ligorio was not of his choice, he did not refuse the assistance of Atty. Ligorio, thus sustaining the trial court's finding that he was assisted by a counsel of his choice. On the validity of Fortunato Pamon's arrest: The Court found Pamon's arrest to be valid, as he admitted being taken into custody by virtue of a warrant of arrest issued by a judge who had convicted him in a prior murder case. On the conviction of Gerson Dulang: The Court reversed and set aside Dulang's conviction. It held that the prosecution failed to establish Dulang's guilt beyond reasonable doubt. Apart from Pamon's extrajudicial confession, there was no other evidence directly linking Dulang to the crime. The testimonies of the victim's widow and employees were deemed too tenuous to support a conviction. The Court emphasized the principle of res inter alios acta, stating that an extrajudicial confession is binding only upon the confessant and is not admissible against co-accused because they have no opportunity to cross-examine the confessant, making it hearsay as against them. The Court also noted that Pamon's confession was repudiated during the trial and that Pamon had no personal knowledge of Dulang's participation, only hearing it from "Dodo," making it double hearsay with respect to Dulang. On the amended information and arraignment of Gerson Dulang: While the issue was raised by Dulang, the Court did not explicitly rule on it as it reversed his conviction on the ground of insufficient evidence. However, the reversal of conviction rendered the procedural issue moot.
Main Doctrine
An extrajudicial confession is binding only upon the confessant and is not admissible against his co-accused because the latter has no opportunity to cross-examine the confessant, rendering it hearsay as against him. The principle of res inter alios acta applies, meaning the rights of a party cannot be prejudiced by an act, declaration, or omission of another.