G.R. No. L-11892; October 31, 1960
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. YAKAN LABAK, YAKAN ABDULA, YAKAN AMANG, YAKAN BUSLOT and YAKANIMAN MAALIM, defendants-appellants.

FACTS

The defendants-appellants were charged with the murder of Jose Atilano, the general manager of the American Rubber Company. On November 18, 1953, Atilano and others were ambushed in a company jeep on the way to a logging camp in Basilan City. An armed man, later identified as appellant Yakan Abdula, pointed a gun at the jeep. As passengers jumped out, firing was heard and Atilano was hit. He later died from his wounds, and his wristwatch and a package of medicine were missing. Eyewitnesses, including driver Estanislao Falcasantos and passenger Jose Fermin, Jr., recognized some of the assailants as individuals who had been loitering near the company premises. An investigation by PC Lt. Alfredo Caoili led to appellant Yakan Labak, who admitted participation and named his companions: Buslot, Abdula, and Amang. Abdula confessed to being the triggerman, and Amang affirmed their complicity. Their extrajudicial confessions were taken and later sworn to before a municipal judge. The murder weapon (a paltik shotgun) and two barongs used in the ambush were recovered based on these confessions. Appellant Yakaniman Maalim was subsequently arrested and gave a sworn statement, revealing that he was prompted by two Moros, Sandung and Mustaman, to propose the murder for a reward of P200.00 to the other appellants, with an additional P100.00 intended for himself. During the trial, appellants Labak, Abdula, and Amang claimed their confessions were obtained through force and intimidation, alleging they were boxed, hit with rifle butts, and subjected to other tortures. The trial court acquitted one accused (Abdul) for insufficiency of evidence but convicted the five appellants of murder, considering the aggravating circumstances of uninhabited place and by a band, offset by the mitigating circumstance of lack of instruction, and sentenced each to life imprisonment and indemnity.

ISSUE

The primary issues are: (1) the admissibility of the extrajudicial confessions of appellants Labak, Abdula, Amang, and Iman Maalim, which were allegedly obtained through force and intimidation; and (2) the sufficiency of evidence to establish the guilt of all appellants, including conspiracy.

RULING

The Supreme Court affirmed the conviction with modification. It held that the extrajudicial confessions were admissible and voluntarily given. The Court found appellants’ claims of maltreatment not credible due to the absence of medical certificates or pronounced physical injuries, the lack of motive for the investigating officers to abuse them, and the fact that they did not report any maltreatment to the municipal judge before whom they swore to their confessions. The confessions were corroborated by the recovery of the murder weapon and barongs, and by positive eyewitness identification. The guilt of appellant Buslot, who did not give a confession, was established beyond reasonable doubt through the positive identification by eyewitness Falcasantos and the declarations of his co-conspirators in their confessions. Conspiracy was clearly established, making the act of one attributable to all. The Court agreed with the trial court’s consideration of the aggravating circumstances of uninhabited place and by a band as one single aggravating circumstance, offset by the mitigating circumstance of lack of instruction. The indemnity to the heirs of the victim was increased from P3,000.00 to P6,000.00. The decision of the trial court was thus modified regarding the indemnity and affirmed in all other respects.