GR 30577; (July, 1981) (Digest)
G.R. No. L-30577 July 24, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RICARTE OBEDOZA, et al., accused, AMBROCIO SUMALBAG and LONDRING MARTINEZ, accused-appellants.
FACTS
On May 28, 1967, in Barrio Salagusog, Cuyapo, Nueva Ecija, armed men stole four carabaos and a cow from Maximiniano Cabangcala. During the incident, Cabangcala was shot and later died from his injuries. Initial police investigation yielded no suspects. Months later, in October 1967, the Cuyapo police apprehended Lauro Alcantara in Balungao, Pangasinan. While in custody, Alcantara executed a sworn confession implicating himself and several others, including appellants Ambrocio Sumalbag and Londring Martinez. Alcantara identified Ben Bocasas as the shooter and Quines Linda as the seller of the stolen cattle. He also pointed to Sumalbag as the group’s informant. Based largely on this extrajudicial confession and another from co-accused Ricarte Obedoza, an information for Robbery in Band with Homicide was filed. Only Alcantara, Sumalbag, and Martinez were arraigned and tried. The trial court convicted all three, sentencing them to life imprisonment.
ISSUE
Whether the guilt of appellants Ambrocio Sumalbag and Londring Martinez was proven beyond reasonable doubt based on the evidence presented, particularly the extrajudicial confessions of their co-accused.
RULING
No. The Supreme Court reversed the conviction and acquitted appellants Sumalbag and Martinez. The Court held that the trial court’s judgment rested almost entirely on the extrajudicial confessions of co-accused Lauro Alcantara and Ricarte Obedoza. These confessions were inadmissible against the appellants, as an extrajudicial confession is binding only on the confessant and is not competent evidence against his co-accused. The prosecution failed to present any independent evidence to corroborate the appellants’ alleged participation in the crime. The Court found serious doubts regarding the voluntariness and credibility of the confessions themselves, noting inconsistencies and the circumstances under which they were obtained. Without the confessions, there was no evidence linking Sumalbag and Martinez to the robbery and homicide. The presumption of innocence must prevail when the evidence does not establish guilt beyond reasonable doubt. Consequently, the constitutional right of the appellants to be presumed innocent was violated by their conviction based on insufficient and inadmissible evidence.