People v. Ramos
REITERATIONFacts
The Antecedents: The appellant, Santiago Ramos, and his co-accused, Santiago Jacinto, were charged with murder. The crime occurred at night in an uninhabited place. The deceased was found in a dying condition by Faustino Ramos, who was unable to ascertain the aggressor due to the deceased's condition. The Constabulary authorities, suspecting the appellant, searched for him, and he was found the following morning with his co-accused. Blood stains were observed on the appellant's undershirt, leading to their arrest. Procedural History: The Court of First Instance of Bulacan acquitted Santiago Jacinto but convicted Santiago Ramos of homicide, sentencing him to twelve years and one day of reclusion temporal, with indemnity and costs. Two written declarations, one by the appellant and one by his co-accused, were presented as evidence. The defense attempted to prove that these confessions were not read to them, contradicting the clerk of court's testimony. Both the appellant and his co-defendant testified that the former acted in self-defense. The trial judge relied on the written declarations and rejected the self-defense theory. The Petition: The appellant appealed the decision, raising two issues: the admissibility of his written declaration and the sufficiency of the evidence to sustain his conviction.
Issue(s)
Whether the testimony of the clerk of court was sufficient to prove that the appellant's confession was made freely and voluntarily. Whether the evidence presented was sufficient to sustain the conviction for homicide, particularly in light of the claim of self-defense.
Ruling
The Supreme Court affirmed the judgment of the trial court, holding that the evidence was sufficient to sustain the conviction for homicide and that the appellant failed to establish self-defense. The Court also found the written declaration admissible.
Ratio Decidendi
On the admissibility of the written declaration: The Court held that the contention that the clerk of court's testimony was insufficient to prove the voluntary nature of the confession was predicated on former rulings based on Section 4 of Act No. 619, which had been repealed by the Administrative Code of 1917. Following the repeal, the burden of proof shifted to the accused to establish that a written confession was not voluntarily given or was obtained by undue pressure. Furthermore, the Court noted that the confession was admitted without objection, and a confession offered in evidence without objection is regarded as prima facie voluntary. The defense had the opportunity to rebut the confession, and the trial court's reliance on it implied a denial of any motion to strike it out. The Court emphasized that while it scrutinizes extrajudicial confessions, the admissibility is primarily for the trial judge. On the sufficiency of evidence and self-defense: The Court reiterated that the burden of proof is upon the accused to establish the acts constituting self-defense. The only evidence presented by the defense was the testimony of the appellant and his co-accused, claiming the deceased struck first and a fair fight ensued. However, the appellant suffered no injuries, and his claim of contusions was not supported by the evidence. After a careful review, the Court was satisfied that the appellant failed to establish self-defense by a preponderance of evidence. The Court also found no reason to interfere with the trial court's finding regarding the existence of a mitigating circumstance under Article 13 of the Revised Penal Code.
Main Doctrine
The burden of proof is upon the accused to establish that a written confession or admission attributed to him was not voluntarily given or was obtained by undue pressure, following the repeal of former Section 4 of Act No. 619 by the Administrative Code of 1917. Furthermore, a confession offered in evidence and not objected to by the defendant is regarded as prima facie voluntary.