G.R. No. 33045 , August 15, 1930
PEOPLE OF THE PHILIPPINE ISLANDS vs. MARTIN BANTAGAN, ET AL.

FACTS

The defendants-appellantsMartin Bantagan (alias Martes), Luis Bantagan, Marcos de la Cruz, and Francisco Ferminowere convicted of murder for the killing of Raymundo de los Santos. The deceased was found dead in his house, with injuries indicating violent death. Martin Bantagan, motivated by resentment because the deceased had taken his daughter as a mistress, conspired with his son Luis and the other appellants to kill Raymundo. On July 18, 1929, the group went to Raymundo’s house, where Luis struck him on the neck with a stick, and Martin delivered another blow. Afterward, they wrapped the body in a mat and took ₱0.90 from the victim’s purse. The appellants confessed to the crime, though Luis later gave a conflicting statement implicating Francisco Fermino as the one who struck the fatal blow. The trial court convicted Martin as principal and the others as accomplices, sentencing them accordingly and ordering indemnity to the heirs.

ISSUE

1. Whether the confessions of the appellants, without independent proof of the corpus delicti, are sufficient to sustain their convictions.
2. Whether the trial court correctly imposed the indemnity in accordance with the Penal Code.

RULING

1. Yes, the confessions are admissible and sufficient for conviction. The rule requiring independent proof of the corpus delicti does not necessitate evidence establishing every element of the crime apart from the confession. It only requires some evidence tending to show the commission of a crime to guard against false confessions. Here, the condition of the body (discoloration on the neck, protruding eyeball, and blood from the ear) provided sufficient independent evidence of violent death, corroborating the confessions. Thus, the confessions were properly considered.

2. The indemnity award was modified. The trial court’s indemnity order did not fully comply with Article 125 of the Penal Code. The Supreme Court amended it as follows:
– Martin Bantagan (principal) is primarily liable for ₱500 to the heirs. In case of his insolvency, the three accomplices are jointly and severally secondarily liable.
– Luis Bantagan, Marcos de la Cruz, and Francisco Fermino (accomplices) are jointly and severally liable for another ₱500. In case of their insolvency, Martin Bantagan is secondarily liable.

The judgment was affirmed with modifications regarding the indemnity. Three justices dissented, arguing that the evidence was insufficient to convict Luis Bantagan as an accomplice, but they concurred with the rest of the decision.