G.R. Nos. L-36436-38 October 23, 1981
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAURO VERGES, et al., defendants, ALFREDO LARCADA, appellant.

FACTS

This case involves the automatic review of three death sentences imposed on appellant Alfredo Larcada for the murder of three inmates. The prosecution’s version established that on May 4, 1969, at the New Bilibid Prisons, approximately sixty-five prisoners from the Sigue-Sigue Sputnik gang were being escorted when Larcada and seventeen other inmates from Cell No. 4-C suddenly rushed out and attacked them with improvised weapons. The assault resulted in the deaths of Alberto Rubiso, Pedro Trejo, and Jaime Caballero. Larcada was implicated based primarily on an extrajudicial confession (Exhibit “E”) he executed before prison investigators, wherein he admitted stabbing two victims and detailed the planning and execution of the attack as an act of retaliation.
The defense, however, contested the admissibility and voluntariness of this confession. Larcada claimed he was coerced, alleging he was severely beaten and maltreated by prison guards to extract the statement. He testified that he only signed the prepared document out of fear and duress. The trial court rejected this defense, finding the confession to be rich in details known only to a participant and bearing the earmarks of voluntariness, and consequently convicted him.

ISSUE

The core issue is whether the extrajudicial confession of the appellant was voluntarily given and admissible as evidence to sustain his conviction for murder beyond reasonable doubt.

RULING

The Supreme Court reversed the judgment of conviction and acquitted Alfredo Larcada. The legal logic centered on the fundamental requirement of proving the corpus delicti independently of an extrajudicial confession and the Court’s stringent duty to scrutinize the voluntariness of such confessions, especially in capital cases. While the confession was executed before the 1973 Constitution’s counsel requirement took effect, and thus prospectively did not violate it, the Court emphasized that the constitutional safeguard recognized a prevalent evil in custodial interrogations that courts must vigilantly guard against.
The Court found the trial court’s reliance on the confession’s detailed nature insufficient to establish voluntariness. Crucially, the prosecution failed to present any corroborative evidence, such as eyewitness testimony from the numerous prison guards present or the other inmates involved, to substantiate the confession’s truthfulness. The claim of maltreatment was not convincingly rebutted by the prosecution. Furthermore, the investigator had prior knowledge from interrogating other suspects, which could have informed the details in Larcada’s statement, undermining the trial court’s inference that the details proved voluntariness. In death penalty cases, the Court requires proof of guilt beyond the slightest vestige of doubt. The evidence, resting solely on a contested confession without independent corroboration, failed to meet this exacting standard. Preferring to err on the side of saving a life, the Court ruled that guilt was not proven beyond reasonable doubt.