GR 26182; (May, 1971) (Digest)
G.R. No. L-26182 May 31, 1971
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TOMAS BAGASALA, JUANITO BAGASALA, ANICETO RONAN, SALVADOR RONAN and ANICETO REX, defendants, JUANITO BAGASALA, defendant-appellant.
FACTS
The case involves the robbery of the house of Macario Ongkit and his wife Juliana Reginaldo in Barrio Cadlan, Pili, Camarines Sur, in the early morning of June 10, 1961. Five men entered the house. Macario Ongkit was attacked and lost consciousness after being wounded. Upon regaining consciousness, he learned his wife had been killed and a sack of rice valued at ten pesos was stolen. Ongkit positively identified appellant Juanito Bagasala and Tomas Bagasala as among the perpetrators, specifically testifying that Juanito wrested an iron pipe from him and used it to beat Juliana, who pleaded with him by name. The incident was reported, leading to the arrest of the accused.
At trial, the prosecution presented Ongkit’s eyewitness testimony and an extra-judicial confession allegedly executed by Juanito Bagasala. The defense contended this confession was involuntary, having been extracted through torture and the infliction of body injuries. Juanito Bagasala also interposed the defense of alibi. The lower court convicted him of robbery with homicide and serious physical injuries, relying on both the confession and the positive identification.
ISSUE
The core issue is whether the conviction of appellant Juanito Bagasala for robbery with homicide and serious physical injuries can be sustained despite the claim that his extra-judicial confession was involuntarily obtained.
RULING
Yes, the conviction is affirmed. The Supreme Court agreed with the appellant that the extra-judicial confession was inadmissible. The constitutional guarantee against self-incrimination renders involuntary confessions, those obtained through physical coercion, intimidation, or promise of leniency, invalid as evidence. The Court found credible evidence supporting the appellant’s claim of maltreatment, noting his failure to recant the confession immediately after its alleged coercive extraction did not necessarily prove voluntariness, as fear of his captors could have persisted.
However, the conviction stands because it was not based solely on the invalidated confession. The Court emphasized that the positive, clear, and convincing eyewitness testimony of the victim, Macario Ongkit, provided sufficient independent basis for finding guilt beyond reasonable doubt. Ongkit identified Juanito Bagasala as one of the assailants who beat his wife. This testimonial evidence was deemed weighty and credible. Conversely, the defense of alibi was rejected for being inherently weak and unconvincing when pitted against such positive identification. The penalty of reclusion perpetua was affirmed, with the indemnity to the heirs of the deceased increased to P12,000.00.