GR 38942; (November, 1933) (Digest)
G.R. No. 38942 ; November 14, 1933
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. HIGINO LAUAS, defendant-appellant.
FACTS
The appellant, Higino Lauas, was convicted of homicide for the killing of Juanito Mangeyew, a 13- or 14-year-old Igorot boy whose hacked body was found on June 28, 1932. The prosecution’s case relied primarily on Lauas’s extrajudicial confession, made before a justice of the peace, wherein he admitted to killing the boy with a bolo as an act of revenge for a prior wounding of his cousin. Corroborating testimony came from Malota, an acquaintance, who testified that Lauas confessed to him about having killed someone shortly after the incident. At trial, the defense claimed Lauas’s confession was extracted through duress and physical mistreatment by Constabulary officers, alleging he was forced to “sit on air” and was assaulted. Both Lauas and Malota testified to this maltreatment, with Malota later recanting part of his testimony on cross-examination.
ISSUE
Was the conviction of Higino Lauas for homicide valid, considering the claim that his confession was obtained through duress and the alleged unreliability of the corroborating testimony?
RULING
No. The Supreme Court reversed the conviction and acquitted Higino Lauas. The Court found the evidence insufficient to establish guilt beyond reasonable doubt. The extrajudicial confession was deemed unreliable due to strong indications it was obtained through intimidation and physical mistreatment, as supported by the testimony of both the appellant and the witness Malota. Furthermore, Malota’s testimony was inconsistent and vacillating, having been given under the influence of fear, rendering it untrustworthy. With no other corroborative evidence presented by the prosecution, the confession alone could not sustain a conviction. The Court emphasized the presumption of innocence and held that the prosecution failed to overcome the reasonable doubt created by the circumstances surrounding the confession and the witness’s recantation.
AI Generated by Armztrong.