G.R. No. L-34247 July 25, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDGARDO MARIÑO Y PARENTO, defendant-appellant.

FACTS

The case involves the robbery and killing of civil engineer Enrique Fallarme on December 27, 1970, in Paco, Manila. The victim, last seen by his son Llywelyn, was later found dead with multiple stab wounds, his Seiko watch and wallet missing. Police investigation led to the arrest of Antonio Madlangbayan, who confessed in a written statement that he, along with appellant Edgardo Mariño and two others, all members of the “Bahala Na Gang,” perpetrated the crime. Madlangbayan’s case had been separately decided, with his conviction affirmed by the Supreme Court.
Based on Madlangbayan’s statement, police arrested Mariño. After a police line-up where Madlangbayan identified him, Mariño gave a detailed extra-judicial confession before Patrolman Carag and later ratified it before Fiscal Ramon Mabutas. In his confession, Mariño narrated how the group approached the victim, announced a hold-up, took his wallet and watch, and stabbed him when he resisted. At trial, Mariño repudiated his confession, claiming it was extracted through force and intimidation.

ISSUE

The primary issues were: (1) the admissibility of co-accused Madlangbayan’s extra-judicial confession against Mariño; and (2) the voluntariness and sufficiency of Mariño’s own extra-judicial confession to sustain his conviction for robbery with homicide.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua due to lack of the necessary votes for the death penalty. The Court held that while Madlangbayan’s confession was inadmissible as evidence against Mariño, it served to corroborate Mariño’s own confession by showing interlocking details of the crime. The Court found Mariño’s confession voluntary and admissible. It was replete with specific details only a participant would know, given before the effectivity of the 1973 Constitution, and solemnly affirmed before a fiscal who verified its voluntariness.
The confession was sufficiently corroborated by the corpus delicti, established through the testimonies of the victim’s son, the police investigator, and the medical examiner, along with the necropsy report proving the robbery and homicide. The aggravating circumstance of abuse of superior strength was correctly appreciated, as four assailants, two armed, attacked an unarmed victim. However, the death penalty was commuted to reclusion perpetua, and the civil indemnity was increased to P30,000.00.