G.R. No. 140268; September 18, 2000
People of the Philippines, plaintiff-appellee, vs. Jose Llanes y Pabico, Allan Rinon y Pabico, Roland Gamba y Pabico, Homeriano Dayaon y Pabico, and Oscar Pabico y De Austria, accused-appellants.

FACTS

On October 12, 1992, the victim, Jaime Cootauco, Jr., and his companions were at a beerhouse in Daet, Camarines Norte. The appellants were also present, engaged in a noisy drinking session. Cootauco, feeling unwell, left to rest in a nearby beach cottage. Subsequently, the appellants also exited the beerhouse. Shortly after, shouts were heard, prompting Cootauco’s friends to investigate. They witnessed the appellants mauling Cootauco inside the cottage, with Roland Gamba striking the victim’s head with a lead pipe while the others held and kicked him. The assailants fled, and the victim, suffering severe head injuries, later died in the hospital.
During police investigation, appellant Roland Gamba executed an extra-judicial confession admitting to the killing, which was signed in the presence of his counsel, Atty. Winston Racoma. The appellants were charged with Murder, qualified by treachery and abuse of superior strength. The Regional Trial Court convicted all appellants, sentencing them to reclusion perpetua. They appealed, contesting the credibility of the eyewitnesses and the validity of Gamba’s confession.

ISSUE

The core issue is whether the prosecution proved the guilt of all appellants beyond reasonable doubt, particularly in light of the challenged eyewitness identification and the admissibility of an extra-judicial confession against co-accused.

RULING

The Supreme Court affirmed the conviction. The positive identification by prosecution witnesses Cambronero, Cabezudo, and Llanto was deemed credible and consistent. They clearly saw the appellants’ faces under bright moonlight and recognized them as the same group from the beerhouse, describing their specific roles in the attack. The Court found no improper motive for these witnesses to falsely testify.
Regarding Gamba’s extra-judicial confession, the Court ruled it was admissible as evidence against him. It was executed voluntarily and with the assistance of counsel, Atty. Racoma, who affirmed that no force or intimidation was used. While a confession is generally admissible only against the confessant, the independent and credible eyewitness accounts sufficiently established the conspiracy and direct participation of all appellants. The qualifying circumstance of abuse of superior strength was correctly appreciated, as the appellants, acting in concert, used their combined strength to overpower the helpless victim. Thus, the crime was properly qualified as Murder.