G.R. No. L-23464 October 31, 1969
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GAVINO DORADO Y ARABACA, defendant-appellant.

FACTS

On September 2, 1962, a five-door apartment and an adjacent house on Castillejos Street, Quiapo, Manila, owned by Mr. and Mrs. Ildefonso Tierra, were burned. The fire resulted in the death of 21 persons and injuries to 5 others. On September 4, 1962, the appellant, Gavino Dorado y Arabaca, who had surrendered to the Mayor of Malabon, Rizal, and was turned over to the Manila Police, gave a handwritten confession (Exhibit C) in the presence of several newspaper reporters. In this confession, he stated he was drunk, had a grievance against the apartment owner, bought gasoline, poured it in the apartment, and set it on fire. He then fled, eventually surrendering in Malabon. He later gave a more detailed sworn statement (Exhibit A) to a police investigator and reenacted the crime. An information was filed charging him with Arson with Multiple Homicide and Multiple Frustrated Homicide. The trial court convicted him based primarily on these extrajudicial confessions and sentenced him to reclusion perpetua. On appeal, the appellant repudiated his confessions, claiming they were extracted through force and intimidation by the police, and denied committing the crime.

ISSUE

Whether the trial court erred in convicting the appellant based on his extrajudicial confessions, which he claims were involuntarily given due to force and intimidation.

RULING

The Supreme Court affirmed the decision of the trial court, holding that the confessions were voluntary and admissible. The Court found no error in the trial court’s rejection of the appellant’s claim of coercion. The voluntariness of the handwritten confession (Exhibit C) was bolstered by the presence of newspaper reporters during its execution, and the appellant showed no signs of injury. The sworn statement (Exhibit A) was given before an assistant city fiscal without any protest or hesitation from the appellant. The detailed contents of the confessions included particulars only the appellant could have known, negating the possibility of police fabrication. The Court upheld the settled rule that factual findings of the trial court, including the credibility of witnesses and the voluntariness of a confession, are accorded great weight on appeal. The confession, supported by the corpus delicti (the fact of the burning and its deadly consequences), was sufficient to sustain the conviction even without an eyewitness. The decision was affirmed with costs against the appellant.