GR 37737; (March, 1933) (Digest)
G.R. No. 37737; March 17, 1933
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. FLAVIANO FLORES, ET AL., defendants. DOMINGO SORATOS and ELEUTERIO PASCUA, defendants-appellants.
FACTS
Domingo Soratos and Eleuterio Pascua, along with others, were convicted of robbery in band with less serious physical injuries for attacking a house in Rosales, Pangasinan. They appealed, contesting the admissibility of their extrajudicial confessions. The appellants, who are illiterate, claimed their thumb-marked confessions were obtained involuntarily—Pascua alleged his hand was forced onto the document, and Soratos gave similar testimony. The prosecution witnesses, the chief of police and a notary public, testified that the confessions were read to and understood by the appellants before they voluntarily affixed their thumb marks.
ISSUE
Whether the extrajudicial confessions of the appellants were voluntarily made and admissible as evidence against them.
RULING
Yes, the confessions were admissible. The Supreme Court found no reason to impeach the credibility of the prosecution witnesses who testified that the confessions were read to and understood by the appellants before they were thumb-marked. The Court noted that while the appellants were ignorant of their constitutional rights against self-incrimination and to due process, the evidence established they understood the confessions. The corpus delicti was proven, and there was corroborating evidence. However, the penalty was modified. Applying Article 503(5) of the Penal Code (equivalent to Article 294(5) of the Revised Penal Code), the sentence was reduced to six years, ten months, and one day of prision mayor. The judgment was affirmed with this modification.
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