People v. Lamadrid
REITERATIONFacts
The Antecedents: The Gumaus Placer Company owned a dredge in Ambos Camarines. On January 16, 1913, a quantity of auriferous sand or amalgam, valued at P800 and containing about 500 ounces of gold, was stolen from the dredge after its depository door was forced open. Procedural History: The accused, including appellant Juan Yebra, were convicted of robbery by the Court of First Instance of Ambos Camarines and sentenced to imprisonment, indemnity, and costs. The Appeal: Juan Yebra appealed the decision of the Court of First Instance, challenging his conviction.
Issue(s)
Whether the confession of the appellant, Juan Yebra, obtained allegedly through promises made by a police officer, is admissible in evidence. Whether there is sufficient evidence, independent of the alleged confession, to sustain the conviction of Juan Yebra for robbery.
Ruling
The Supreme Court affirmed the judgment of conviction against Juan Yebra. The Court found that while the written confession was inadmissible due to promises made by a police officer, there was abundant independent evidence to sustain the conviction.
Ratio Decidendi
On Issue 1: The Court held that the written confession made by Juan Yebra before a notary public was inadmissible. This was because the confession was allegedly procured by promises made by a police officer who stated that nothing would happen to Yebra if he confessed. The Court noted that this evidence was uncontradicted and therefore regarded the confession as inadmissible. On Issue 2: Despite the inadmissibility of the written confession, the Court found abundant evidence to sustain the conviction. This included the testimony of Sotero Galero and Mariano Banal, who saw Yebra and Perfecto Lamadrid near the dredge with a sack, and later at Lucas Rojo's house discussing the sack of sand. Yebra was observed to be substantially nude with wet clothing, and his hat, found at Rojo's house, contained auriferous sand. Furthermore, witness Marcelo Venita testified that Yebra delivered gold nuggets to him for jewelry. The Court also considered the testimony of the chief of police regarding a conversation with Lamadrid and Yebra in jail, where they offered jewelry and money to be set free, and their subsequent actions in leading the chief to the hidden valuables, which Yebra stated was obtained from the dredge. The Court found this latter statement voluntary and without force, intimidation, deceit, or promise.
Main Doctrine
Confessions obtained through promises of leniency or threats are inadmissible in evidence. However, a conviction may be sustained by other competent evidence even if a confession is excluded, provided such evidence is sufficient to prove guilt beyond reasonable doubt.