G.R. No. L-36510 May 17, 1980
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO VIDUYA Y VIDUYA, accused.

FACTS

On July 3, 1972, the body of 17-year-old Leonida Rivera was discovered in a river in Barrio Lloren, Tubao, La Union. It was partially submerged, covered with rice straw, and weighed down by stones. An autopsy revealed lacerated hymen and determined death was caused by asphyxia due to strangulation. The investigation led to Antonio Viduya, a farmer from the same barrio. On July 4, 1972, after his arrest, Viduya executed a sworn confession in Ilocano before a municipal judge. He detailed how, on July 1, he forcibly raped Leonida by a riverbank while strangling her, and subsequently concealed her body.
The prosecution established that Leonida went missing on July 1 after leaving to gather weeds. Her clothing, umbrella, and slippers were found along a creek, and Viduya’s scabbard was recovered nearby. Viduya initially pleaded guilty at the preliminary investigation but entered a not guilty plea at his trial before the Court of First Instance. He repudiated his confession, claiming maltreatment, and presented an alibi. The trial court convicted him of rape with homicide, sentenced him to death, and the case was elevated for automatic review.

ISSUE

The core issue is whether the extrajudicial confession of the accused is admissible as evidence against him.

RULING

The Supreme Court affirmed the conviction and the death penalty. The Court ruled that Viduya’s extrajudicial confession was admissible and voluntarily made. His claim of maltreatment was found not credible, as it was contradicted by the detailed nature of the confession itself and the testimonies of the police officer who took it and the municipal judge before whom it was sworn. The judge’s certification noted Viduya spontaneously acknowledged the confession, and a medical examination revealed an abrasion on Viduya consistent with the victim’s struggle, corroborating his account.
Crucially, the Court held that the constitutional provision (Section 20, Article IV of the 1973 Constitution) requiring the right to remain silent and to counsel, and rendering involuntary confessions inadmissible, could not be applied retroactively. The confession was obtained on July 4, 1972, while the Constitution took effect only on January 17, 1973. Following precedent, such constitutional safeguards do not apply to confessions taken before its effectivity. The confession, corroborated by physical evidence and the implausibility of his alibi, established his guilt beyond reasonable doubt for the complex crime of rape with homicide. The penalty of death, being indivisible, was properly imposed.