People v. Ampal
REITERATIONFacts
The Antecedents: Early in the morning of November 17, 1934, in Mandulog, Lanao, Bakang Dianal was suddenly assaulted by a group of armed Moros, resulting in his instant death due to multiple wounds. Procedural History: Three individuals were charged with murder. One pleaded guilty, another was acquitted, and the appellant, Masiñger Ampal, was found guilty by the Court of First Instance of Lanao. The Appeal: Masiñger Ampal appealed the decision, alleging that the trial court erred in admitting his written confession (Exhibit B), in holding that the confession genuinely represented his participation in the crime, and in convicting him based on the evidence presented.
Issue(s)
Whether the written confession of the appellant was admissible in evidence. Whether the trial court erred in holding that the written confession was a genuine representation of the appellant's participation in the crime. Whether the appellant was guilty of murder based on the evidence presented.
Ruling
The judgment of the Court of First Instance of Lanao finding the appellant guilty of murder is affirmed. The extreme penalty of death could have been imposed, but due to the lack of unanimity among the justices of the division regarding the death penalty, the case was not submitted to the Court en banc for the imposition of such penalty.
Ratio Decidendi
On the admissibility of the confession (Exhibit B): The Court held that the principal contention of the appellant, that his confession should not have been admitted because he was in confinement and not cautioned, is without merit. The old English rule requiring such caution is not in force in the Philippines. A confession may be used if voluntarily made. Evidence showed the appellant expressed anxiety to confess to a Constabulary lieutenant and the chief of police. The confession, made in the Visayan dialect, was written and thumb-printed by the appellant before the justice of the peace. While the appellant testified he thumb-printed believing it would set him free, he did not testify that any official made such a promise. His subsequent statements to his wife and his actions towards the deceased's family (kissing their hands, signifying begging pardon according to Moro custom) further indicated the voluntary nature and sincerity of his confession. On the genuineness of the confession and conviction: The Court found that the confession, Exhibit B, was a genuine representation of the appellant's participation. Outside of those who committed the crime, there were no eyewitnesses to the killing itself. However, the wife and nephew of the deceased, who ran to the scene upon hearing cries for help, saw three persons running away and identified the appellant among them. The deceased was a prominent man with prior troubles over a woman and land. The wife testified that the appellant had previously warned her husband to watch out or he would be killed. The affidavit, Exhibit B, established that the killing was planned, thus proving evident premeditation. Furthermore, the confession detailed that the assailants lay hidden along the path known to be used by the deceased, and the deceased was suddenly attacked from such ambush, establishing treachery (alevosia). The evidence, including the confession and eyewitness identification, proved the guilt of the accused for murder beyond reasonable doubt. On the imposition of the death penalty: The Court noted that under the circumstances, the extreme penalty of death could be awarded. However, as the five justices of the division were not unanimous in their belief that the death penalty should be imposed, the case was not submitted to the Court en banc for the purpose of awarding such penalty. This reflects the procedural requirement for the imposition of the death penalty, which necessitates a unanimous vote.
Main Doctrine
Extrajudicial confessions are admissible in evidence if they are voluntarily made, even if the accused was not informed that the confession could be used against them, provided no undue influence, threat, or promise was employed. Furthermore, the crime of murder is established when the killing is perpetrated with treachery, characterized by the employment of means, methods, or forms in the execution thereof which tend directly and specially to ensure its execution without risk to the assailant arising from the defense which the offended party might make, and evident premeditation, which requires proof that the offender had previously planned the commission of the crime.