G.R. No. 110106 July 31, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENATO MONTIERO Y RAMIREZ, accused-appellant.

FACTS

Accused-appellant Renato Montiero was charged with Robbery with Homicide for robbing and killing Imelda Umali in Agdangan, Quezon, on January 3, 1991. After initially pleading not guilty, he changed his plea to guilty but later reverted to not guilty, leading to a full trial. The prosecution evidence established that the victim was found dead with her jewelry and cash missing. During the investigation, appellant exhibited suspicious behavior at the victim’s wake. He subsequently confessed orally to the police and later executed a detailed extrajudicial confession (Sinumpaang Salaysay) with the assistance of his chosen counsel, Atty. Adolfo Ilagan, after being fully apprised of his constitutional rights. The confession led to the recovery of the stolen items and the weapon.
At trial, appellant repudiated his confession, claiming it was extracted through threats by SPO Habito. He interposed the defense of alibi, asserting he was at a drinking session nearby during the incident and later blamed his half-brother for the crime. The trial court convicted him based primarily on his extrajudicial confession and sentenced him to reclusion perpetua.

ISSUE

Whether the trial court erred in convicting appellant based on his extrajudicial confession and in rejecting his defenses of alibi and repudiation.

RULING

The Supreme Court affirmed the conviction. The legal logic rests on the validity and admissibility of the extrajudicial confession. The Court meticulously examined the circumstances of its execution and found it compliant with constitutional and procedural safeguards. Appellant was assisted by a counsel of his own choice, Atty. Ilagan, who conferred with him privately for half an hour to explain his rights and the consequences of confessing. The confession was made voluntarily, without evidence of coercion, intimidation, or promise of reward. The Court emphasized the presumption that a confession is given voluntarily unless the accused proves otherwise through clear evidence of violence, threat, or inducement, which appellant failed to do. His relationship with the investigating officer and the presence of his family during the interrogation further undermined his claim of duress.
Regarding his defenses, the Court ruled that alibi is inherently weak and must demonstrate the physical impossibility of the accused’s presence at the crime scene. Appellant’s admission that he was merely 14 meters away negated this impossibility. His alibi was uncorroborated, as he did not present any of the alleged drinking companions or family members to support it. The repudiated confession, being voluntary and corroborated by the recovery of evidence, constituted evidence of a high order. Consequently, the trial court correctly found guilt beyond reasonable doubt.