G.R. No. L-62593. August 31, 1984.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AUGUSTO PIZARRO and BOY MAMURI, (at large) accused, AUGUSTO PIZARRO, accused-appellant.

FACTS

On June 15, 1980, Rogelio Sabalboro heard a gunshot from his brother Cornelio’s house about fifty meters away. While proceeding to investigate, he met three persons, including accused-appellant Augusto Pizarro, coming from the direction of the house. One of them warned Rogelio not to report the incident to the police or his family would be liquidated. The trio then fled towards a forested area. Rogelio later discovered his brother Cornelio dead from a gunshot wound to the head, as confirmed by an autopsy report.
The prosecution presented Rogelio’s testimony, the autopsy report, and the testimony of PC Sgt. Laureano Luzaran, who identified appellant Pizarro’s sworn extra-judicial confession (Exhibit “E”). In this confession, Pizarro admitted acting as an “alalay” (lookout) in the killing of Cornelio Sabalboro, which was motivated by a land dispute, and that he received part of a P400.00 payment for the act. The defense waived its right to present evidence and filed a memorandum instead.

ISSUE

Whether the trial court erred in convicting appellant Pizarro of murder based on the testimony of Rogelio Sabalboro and the admissibility of his extra-judicial confession.

RULING

The Supreme Court affirmed the conviction. The extra-judicial confession was admissible. The document itself showed that prior to interrogation, appellant was properly informed in Filipino of his constitutional rights to remain silent and to counsel, as required by Section 20, Article IV of the 1973 Constitution. He explicitly waived these rights voluntarily and knowingly. Appellant did not take the witness stand to contest that he understood these warnings or that the confession was involuntary.
An extra-judicial confession is sufficient for conviction if corroborated by evidence of the corpus delicti. Here, the fact of death—the corpus delicti—was conclusively established by Rogelio Sabalboro’s testimony, the PC sergeant’s investigation, and the medical examiner’s necropsy report. Furthermore, Rogelio’s unrebutted testimony placed appellant at the scene fleeing from the victim’s house immediately after the shooting and issuing threats. The defense’s decision not to present evidence left the prosecution’s case uncontroverted. The allegations of murder were duly proven. The penalty of reclusion perpetua was correctly imposed, and the indemnity was increased to P30,000.00.