People v. Tabuche
REITERATIONFacts
The Antecedents: Appellants Taijo Yokimiso and Kumekichi Saito were prosecuted for robbery with homicide along with Takeo Tabuche, who remained a fugitive. The victim, Kiro Zuki Sato, a Japanese store owner, was found dead in Caloocan with multiple wounds. Evidence presented included an autopsy report, testimonies of witnesses who saw the deceased with two Japanese men, and declarations made by the accused under oath before Colonel Dominguez of the Constabulary. Procedural History: The Court of First Instance of Manila found the appellants guilty of robbery with homicide. The judge admitted the extrajudicial declarations of the accused, finding they were made voluntarily and without duress, and that the interpreter faithfully translated their statements. The court also upheld the authority of Colonel Dominguez to administer oaths. The Petition: The appellants appealed the decision, primarily questioning the admissibility of their extrajudicial declarations and the testimony of Colonel Dominguez.
Issue(s)
Whether the extrajudicial declarations of the appellants, Exhibits C and N, were admissible in evidence. Whether the trial court erred in admitting the testimony of Colonel Dominguez. Whether the evidence presented was sufficient to prove the guilt of the appellants for the crime of robbery with homicide beyond a reasonable doubt.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, finding the appellants guilty of robbery with homicide and sentencing them to cadena perpetua. The Court held that the extrajudicial declarations were admissible and that even without these confessions, other evidence was sufficient for conviction.
Ratio Decidendi
On the admissibility of extrajudicial declarations: The Court reiterated the rule that for a confession to be admissible, it must be shown to have been voluntarily made and not obtained through violence, intimidation, threats, or promises of reward or leniency. While Act No. 619, which explicitly stated this, was repealed, the general rule of jurisprudence rejecting confessions obtained under such conditions remains. The burden of proof has shifted to the accused to demonstrate that the confession was not voluntarily given or was obtained by undue pressure. In this case, the Court found no evidence that the declarations were obtained through undue influence, and thus they were properly admitted. The Court also noted that even if the declarations were considered inadmissible against co-accused, they are admissible against the person making them. On the admissibility of Colonel Dominguez's testimony: The Court found no error in admitting the testimony of Colonel Dominguez. Section 21 of the Administrative Code authorizes certain officers, including those appointed by the Governor-General, to administer oaths. Colonel Dominguez, as an officer of the Constabulary, was authorized to administer oaths, and the declarations made before him were thus properly received as evidence. The presence of disinterested persons who were fellow citizens of the accused further supported the voluntariness and regularity of the declarations. On the sufficiency of evidence for conviction: The Court held that even if the extrajudicial declarations were disregarded, the evidence on record was sufficient to prove the guilt of the appellants beyond a reasonable doubt. Their own declarations made at the trial, corroborated by the testimonies of witnesses Maria Castro, Felisa Felipe, and Dequinosoki Tanaka, and by the discovery of blood-stained clothing admitted to be theirs, along with a portion of the stolen money, were deemed sufficient to justify their conviction. The Court found that the appellants directly participated in the commission of the crime, including the violent taking of Sato's life with intent to gain, and the subsequent robbery of his watch and money.
Main Doctrine
Extrajudicial confessions, even if made under oath before a high-ranking officer, are admissible if shown to have been voluntarily made, with the burden of proof shifting to the accused to demonstrate involuntariness. Even without confessions, other evidence may suffice for conviction.