G.R. No. 1751, February 23, 1905
THE UNITED STATES, complainant-appellee, vs. VICENTE LOZADA, ET AL., defendants-appellants.

FACTS:
The defendants-appellants, Vicente Lozada and others, along with Patricio Alvarez (who did not appeal), were charged and convicted in the Court of First Instance for the crime of robbery en cuadrilla. They were sentenced to imprisonment. The prosecution’s evidence consisted solely of confessions made by the appellants on two occasions: first, to Corporal Bernabe Marquez of the Constabulary while they were confined at his station, and second, before the justice of the peace during the preliminary investigation. The appellants, however, recanted these confessions, alleging they were extracted through force, threats, and ill-treatment by Corporal Marquez, including being tied, struck with fists and a revolver, threatened with death, and coerced into maintaining their statements before the justice. Corporal Marquez, during his testimony, admitted to having threatened, abused, and whipped the defendants to obtain their confession.

ISSUE:
Whether the confessions extracted from the appellants through violence, intimidation, and threats are admissible as evidence against them.

RULING:
No. The Supreme Court reversed the judgment of conviction and acquitted the appellants. The Court held that a confession obtained through violence, intimidation, or threats is null and void and cannot be admitted as evidence against an accused. This principle is reinforced by Section 4 of Act No. 619 of the Philippine Commission, which mandates that no confession shall be admissible unless the court is satisfied it was made freely and voluntarily, without violence, intimidation, threat, menace, or promises. The Court found that Corporal Marquez’s admitted actions in torturing the defendants to extract a confession constituted a clear violation of Section 3 of the same Act, which penalizes such conduct. The other alleged evidence, regarding the recovery of stolen property, was discredited by the testimony of the offended party. Consequently, with the confessions being inadmissible and no other competent evidence presented, the appellants were acquitted. The Court also reserved the right of the prosecuting attorney to file the necessary complaint against Corporal Bernabe Marquez for violating Act No. 619.