G.R. No. L-41493 and L-41494 December 14, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TEODORO VILLAMOR, ROMULO POLEÑO and ROMEO CAGARA, accused.

FACTS

Accused Teodoro Villamor, Romulo Poleño, Romeo Cagara, and others conspired to kill Lolito Bernal to seize his firearm. On March 22, 1973, the group, all armed, proceeded to Bernal’s house. Villamor, Poleño, and another barged into the kitchen where Bernal was, demanded his firearm, and upon his denial, took turns hacking him with bolos. Cagara joined the assault. Bernal’s wife, Angeles, witnessed the attack and shouted for help; Poleño fired at her twice but missed. Bernal died from multiple fatal wounds, including a deep neck wound severing blood vessels and a chest wound lacerating his liver. The accused fled but were later captured.
The accused were charged with murder. During trial, they repudiated their extrajudicial confessions, claiming they were extracted through maltreatment and that they were not informed of their constitutional rights to remain silent and to counsel. The prosecution presented the eyewitness testimony of Angeles Bernal and the testimonies of two co-accused who were discharged to become State witnesses. The trial court convicted Villamor, Poleño, and Cagara of murder, sentencing each to death.

ISSUE

Whether the extrajudicial confessions of the accused are admissible as evidence, given their claim of a violation of their constitutional rights during custodial interrogation.

RULING

The Supreme Court affirmed the conviction and the imposition of the death penalty. The Court held that even assuming the extrajudicial confessions were inadmissible for any alleged failure to properly administer the Miranda warnings during custodial interrogation, the conviction remains solidly based on other evidence. The culpability of the accused was proven beyond reasonable doubt by the credible and positive eyewitness identification of Angeles Bernal, who knew the accused personally and vividly recounted the brutal attack. This testimony was corroborated by the declarations of the two State witnesses. The Court found conspiracy evident from the coordinated execution of the plan to kill Bernal. The crime was qualified by abuse of superiority (the accused acting in band) and aggravated by evident premeditation and dwelling. No mitigating circumstances were present. Thus, the guilt of the accused was established independently of the contested confessions, warranting the affirmance of the death penalty for the senseless and premeditated murder.