G.R. Nos. 113022-24; December 15, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TEOFILO SERANILLA y FRANCISCO, LEO FERRER y PADILLA, EDMUNDO HENTOLIA y RETAA, DANIEL ALMORIN y BALBIN AND CARLOS CORTEZ, JR., accused.

FACTS

The case involves the appeal of four accused-appellants from their conviction for four counts of rape with homicide. The victim, Ma. Victoria Santos, was found dead on September 25, 1992, in San Mateo, Rizal. Her naked body was in an advanced state of decomposition with a fatal incised wound on the neck. The prosecution built its case primarily on the extrajudicial confessions of the appellants and the testimony of their co-accused, Carlos Cortez, Jr., who turned state witness. The confessions detailed a conspiracy where the group abducted the victim, took turns raping her, and subsequently killed her by slashing her throat. The appellants later recanted their confessions, claiming they were extracted through torture.
The trial court convicted all accused, sentencing each to four penalties of reclusion perpetua and ordering them to pay indemnity. On appeal, the appellants argued that their extrajudicial confessions were inadmissible, being coerced and uncorroborated. They contended that without these confessions, the evidence was insufficient to prove their guilt beyond reasonable doubt, as no eyewitness directly identified them as the perpetrators of the crime.

ISSUE

The core issue is whether the extrajudicial confessions of the appellants, subsequently repudiated, are admissible and sufficient to sustain their conviction for four counts of rape with homicide.

RULING

The Supreme Court affirmed the conviction. The legal logic rests on the principle that an extrajudicial confession, if voluntarily given and corroborated by evidence of corpus delicti, is admissible and can sustain a conviction. The Court found the confessions detailed, spontaneous, and containing facts known only to the perpetrators, indicating voluntariness. The claim of torture was belied by the appellants’ failure to report any maltreatment when they were presented before a judge for arraignment. Crucially, the confessions were strongly corroborated by the independent evidence of corpus delicti—the victim’s body was found raped and murdered, consistent with the narrative in the confessions. The testimony of state witness Cortez, who actively participated and whose account aligned with the confessions, provided further corroboration. The Court emphasized that the trial court’s assessment of witness credibility is accorded high respect. Consequently, the collective weight of the voluntary confessions, corroborated by the evidence of the crime and a co-conspirator’s testimony, established guilt beyond reasonable doubt. The Court modified the civil liability, increasing indemnity to P100,000 and awarding P50,000 as moral damages for each count.