G.R. No. 100462 September 29, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RUFO LLENARESAS alias “Rafael Llenaresas,” accused-appellant.

FACTS

Accused-appellant Rufo Llenaresas, along with several others, was charged with Robbery with Homicide for the killing of jeepney driver Antonio Maligaya and the taking of his vehicle and valuables on January 31, 1988. Following a tip from an informant, the Lucena City police, in coordination with Marikina police, apprehended Llenaresas and co-accused Romeo Jabil in Marikina without a warrant. During custodial investigation, Llenaresas executed a sworn confession detailing his participation in the crime. He later recanted this confession at trial, claiming it was extracted through force and intimidation.

ISSUE

The core issues are: (1) the admissibility of Llenaresas’s extra-judicial confession, and (2) the effect of his warrantless arrest on the validity of his conviction.

RULING

The Supreme Court affirmed the conviction. On the first issue, the Court upheld the confession’s admissibility, finding it was given voluntarily, with the assistance of counsel, and after a proper waiver was executed. The confession contained rich, corroborative details matching Jabil’s own statement and the physical evidence (like a cap found at the scene), giving it the “ring of truth.” Llenaresas’s claim of coercion was rejected for being uncorroborated; he presented no medical evidence of injury and did not report the alleged beatings to the assisting prosecutor. On the second issue, the Court ruled that any defect in the warrantless arrest was cured by his subsequent submission to the court’s jurisdiction through arraignment and trial. An illegal arrest does not invalidate a conviction based on sufficient evidence. The Court modified the civil liability, increasing the death indemnity to P50,000.00.